who specialized in classical antiquity, was photographed with an ancient Roman sword and laurel wreath. A month after the display was installed, the university's chancellor, Lawrence Ianni, ordered the two photographs removed after complaints from female administrators and faculty, some of whom had been targeted by an anonymous public harassment campaign that year over Ianni's establishment of a Commission on Women. The professors and students sued, and won partial summary judgement holding that Ianni did not have qualified immunity. The defendants cited Waters, but Judge Michael J. Davis ruled that it was not relevant since the case did not involve an adverse employment action. The Eighth Circuit reversed on appeal. Theodore McMillian relied on Waters to give weight to the chancellor's fears of disruption in light of the harassment campaign, noting that "It cannot seriously be disputed that, during that spring 1992 semester, the atmosphere on campus was more tense than normal." C. Arlen Beam rejected that analysis in his dissent, saying those fears were "based on conclusory hearsay and rank speculation". An en banc rehearing in turn reversed that panel. Beam reiterated his arguments in the majority opinion. McMillian, dissenting along with John R. Gibson, who had joined him in the original panel, wrote that the majority had understated the effect of the harassment on the campus in assessing the potential for disruption. Despite the lack of adverse action, it was "no less an employment-related case" than Waters and its related cases, he argued. Ianni, who they felt had qualified immunity in any event due to the lack of settled law where academic freedom was concerned, had had to make a choice between two subordinates' conflicting interests. The messages conveyed by the photographs could clearly have been conveyed through other means, they observed. Shahar v. Bowers Waters was also part of the analysis employed in Shahar v. Bowers, an Eleventh Circuit case brought against Georgia Attorney General Mike Bowers by a woman to whom he had withdrawn a job offer after learning of her plans for a lesbian wedding in 1991, saying it would reflect badly on his office in public opinion to have an employee whose lifestyle involved regularly violating Georgia law against sodomy. After Northern District of Georgia senior judge Richard Cameron Freeman granted Bowers summary judgement on her First and Fourteenth Amendment claims, she appealed. A three-judge panel agreed her right to intimate association had been