years, and that is when the majority of universities started offering formal tenure as a side benefit. The rate of tenure (percent of tenured university faculty) increased to 52 percent. In fact, the demand for professors was so high in the 1950s that the American Council of Learned Societies held a conference in Cuba noting the too-few doctoral candidates to fill positions in English departments. During the McCarthy era, loyalty oaths were required of many state employees, and neither formal academic tenure nor the Constitutional principles of freedom of speech and association were protection from dismissal. Some professors were dismissed for their political affiliations. During the 1960s, many professors supported the anti-war movement against the Vietnam War, and more than 20 state legislatures passed resolutions calling for specific professorial dismissals and a change to the academic tenure system. From 1972 to the present Two landmark U.S. Supreme Court cases changed tenure in 1972: (i) Board of Regents of State Colleges v. Roth, 408 US 564; and (ii) Perry v. Sindermann, 408 US 593. These two cases held that a professor's claim to entitlement must be more than a subjective expectancy of continued employment. Rather, there must be a contractual relationship or a reference in a contract to a specific tenure policy or agreement. Further, the court held that a tenured professor who is discharged from a public college has been deprived of a property interest, and so due process applies, requiring certain procedural safeguards (the right to personally appear in a hearing, the right to examine evidence and respond to accusations, the right to have advisory counsel). Later cases specified other bases for dismissal: (i) if a professor's conduct were incompatible with his duties (Trotman v. Bd. of Trustees of Lincoln Univ., 635 F.2d 216 (2d Cir.1980)); (ii) if the discharge decision is based on an objective rule (Johnson v. Bd. of Regents of U. Wisc. Sys., 377 F. Supp 277, (W.D. Wisc. 1974)). After these cases were judged, the number of reported cases in the matter of academic tenure increased more than two-fold: from 36 cases filed during the decade 1965–1975, to 81 cases filed during the period 1980–1985. During the 1980s there were no notable tenure battles, but three were outstanding in the 1990s. In 1995, the Florida Board of Regents tried to re-evaluate academic tenure, but managed only to institute a weak, post-tenure performance review. Likewise, in