Frye v. Memphis State University

O’BRIEN, Justice,

dissenting.

This case has been litigated for more than eleven years, through seven hearings.1 The trial court ultimately decided that Professor Frye’s firing by Memphis State University was not supported by clear and convincing evidence in violation of T.C.A. § 49-8-303(a)(4), which is the statute governing procedures for the termination of State University and College tenured faculty.

The Chancellor further held that the Professor had a duty to exercise reasonable diligence in seeking employment following the termination of his employment with Memphis State University.

Professor Frye was reinstated effective 21 August 1988. By agreement it was stipulated that damages would be calculated as of 25 September 1979 to be based on lost salary, longevity pay, athletic event discounts, insurance premium costs, pension benefits, prejudgment interest, and costs. The trial court referred the question of damages to a Special Master. After two days of hearings the Master calculated that the Professor was entitled to recover the sum of $429,258.00; representing salary he would have received since being terminated in the amount of $318,062.00, $27,476.00 insurance costs, and $83,720 in interest.

The Master found that Professor Frye’s failure to seek employment during the seven years between his termination and the date of the hearing did not constitute a lack of reasonable diligence with respect to mitigation of damages. The University objected to that finding and the Chancellor agreed. He held that the Professor had a duty to exercise reasonable diligence in seeking employment following termination of his employment with Memphis State University and the maximum period of time during which it was reasonable for him to make no effort to seek employment was one year. He modified the award of damages to the sum of $39,515.00 representing compensation and interest for the academic year 1979 through 1980.

The majority now conclude that, under the unique facts of this case, the failure of Professor Frye to seek employment subsequent to his termination does not constitute failure to exercise reasonable diligence as a matter of law.

Professor Frye conceded he did not seek other employment after being terminated. Although an employee may recover lost wages when wrongfully terminated, there is a duty to minimize this loss by seeking other employment. See Polk v. Torrence, 218 Tenn. 680, 405 S.W.2d 575, 577 (1966). The law does not make exceptions for tenured professors who may or may not have a highly protected employment status. Their duty to abide by the law is precisely the same as is that of the most humble among the working citizens of this State. Professor Frye testified at the trial level that the circumstances surrounding his dismissal would make attempts to find a job futile. The University responds that subsequent to his termination several similar positions were advertised in a higher education publication as being available and his subjective perception as to the futility of a job search does not excuse the complete failure to attempt to mitigate damages by making a reasonable and diligent attempt to locate employment. I agree.

Throughout the course of these proceedings Professor Frye has maintained the termination of his employment was unjust. *176His position has been sustained by the courts, although, perhaps, not as decisively as might be preferred. Nevertheless, it was his obligation to endeavor to convince potential employers that he had been unjustly discharged.

His wrongful termination did not entitle him to sit idly by, doing nothing to ameliorate his situation. I am of the opinion he should not be rewarded for his indolence by payment of nearly a half million dollars. I would affirm the judgment of the Chancellor. Therefore I dissent.

. Before a University Faculty Committee,. the University President, a Board of Regents Personnel Committee, twice in Chancery Court and two times before this Court.