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State University of New York at Fredonia Professor Stephen Kershnar, apart from his faculty duties, authored a biweekly opinion column for the Dunkirk-Fredonia Observer local newspaper. Kershnar's column had been critical of university policies including SUNY Fredonia's Affirmative Action policy; Kershnar also publicly criticized a new student conduct policy. In response, President Dennis L. Hefner denied his promotion to full professor due to his "deliberate and repeated misrepresentations of campus policies and procedures," without presenting evidence of any such violations. Hefner proposed a severely strict arrangement that would indefinitely require Kershnar to get "unanimous consent" from a university committee for all writing about the university, which Kershnar rejected. ²ÝÝ®ÊÓƵAPP¹ÙÍø wrote Hefner on July 7, 2006, but Hefner upheld SUNY Fredonia's denial of Kershnar's promotion. ²ÝÝ®ÊÓƵAPP¹ÙÍø took the case public, however, and Hefner then agreed to reevaluate Kershnar's application. On August 11, 2006, Kershnar was notified of his unconditional promotion to full professor.