the drastic step of eliminating or downsizing some departments, in which case both tenured and untenured faculty are let go. In 1985, the United States Supreme Court decision Cleveland Board of Education v. Loudermill determined that a tenured teacher cannot be dismissed without oral or written notice regarding the charges against him or her. Additionally, the Court held that the employer must provide an explanation of the employer's decision, including a discussion of the employer's evidence, and the teacher must be given an opportunity for a fair and meaningful hearing. Criticisms of tenure for school teachers In 2012, tenure for school teachers was challenged in a California lawsuit called Vergara v. California. The primary issue in the case was the impact of tenure on student outcomes and on equity in education. On June 10, 2014, the trial judge ruled that California's teacher tenure statute produced disparities that "shock the conscience" and violate the equal protection clause of the California Constitution; his ruling was later overturned on appeal. Criticisms of tenure for college professors The American Association of University Professors has handled hundreds of cases where it alleges that tenure candidates were treated unfairly. The AAUP has censured many major and minor universities and colleges for such alleged tenure abuses. Tenure at many universities depends primarily on research publications and research grants, although the universities' official policies are that tenure depends on research, teaching and service. The demand that a professor show exemplary production in research is intense. Unless a professor's research is in pedagogy (for instance within a School of Education), articles in refereed teaching journals and obtaining teaching grants often do not contribute greatly towards tenure, as the research is not focused on the professor's creating new knowledge in his or her home discipline. Business schools also consider contribution to practice, but this is difficult to implement due to a lack of generally accepted criteria and metrics. At some universities the department chairperson sends forward the department recommendation on tenure. There have been cases, such as one case at The University of Texas at San Antonio (2008), where the faculty voted unanimously to tenure an individual but the chairperson sent forward a recommendation not to grant tenure despite the faculty support. Tenure decisions can result in fierce political battles. In one tenure battle at Indiana University, an untenured professor was accused of threatening violence against those who opposed his