Amir Marmarchi v. University of Illinois, 17-1939

Amir Marmarchi, a doctoral candidate in Industrial Systems Engineering at the University of Illinois, had a contentious relationship with his advisor, Prof. Alex Kirlik, including alleged data-pressure, altered submissions, and exclusion from research/teaching positions.
In October 2015 Marmarchi told Associate Dean Anne Kopera he intended to make a "whistleblower complaint" about faculty "fraud;" Kopera advised using the University grievance process.
Two days after Marmarchi’s meeting with the dean, department chair Ramavarapu Sreenivas removed him from the doctoral program and offered a master’s degree instead; Marmarchi later filed the grievance.
Marmarchi sued the University (Board of Trustees), his advisor, and department officials alleging First Amendment retaliation, due-process and various employment/discrimination claims, and FMLA violations; the district court dismissed for failure to state a claim and declined supplemental jurisdiction over state-law claims.
On appeal Marmarchi primarily argued that his dismissal was retaliatory for protected speech (threat to report fraud); the Seventh Circuit reviewed de novo and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
First Amendment retaliation	Marmarchi: removal was retaliation for threatening to file a whistleblower complaint about faculty fraud	Defendants: plaintiff did not plead sufficient, specific protected speech or causal link	Dismissed — allegations about an unspecified threat to report "fraud" fail to plead protected speech or give fair notice
Procedural due process (contract/entitlement)	Marmarchi: University denied procedural protections under its handbook	Defendants: handbook procedures cited were discretionary, not contractual entitlements	Dismissed — no specific contract terms or enforceable entitlement pleaded
Supplemental jurisdiction over state-law claims	Marmarchi: did not press a separate argument on appeal	Defendants: district court appropriately dismissed state claims after federal claims gone	Affirmed — court properly declined to exercise supplemental jurisdiction under ordinary practice
Appointment of counsel	Marmarchi: trial court abused discretion by denying counsel requests	Defendants: Marmarchi did not show diligent attempts to obtain counsel and could litigate pro se	Affirmed — district court did not abuse discretion given Marmarchi’s limited evidence of counsel-seeking and demonstrated capacity to litigate

Brown v. Li, 308 F.3d 939 (9th Cir. 2002) (some graduate-student curricular speech may be unprotected)
Papish v. Bd. of Curators of Univ. of Mo., 410 U.S. 667 (1973) (student political expression protected)
EEOC v. Concentra Health Servs., Inc., 496 F.3d 773 (7th Cir. 2007) (complaint alleging retaliation for unspecified unlawful conduct is insufficient)
Kyle v. Morton High School, 144 F.3d 448 (7th Cir. 1998) (allegations of retaliation for unspecified political advocacy are insufficient)
Charleston v. Bd. of Trs. of Univ. of Ill. at Chicago, 741 F.3d 769 (7th Cir. 2013) (due-process claim for academic dismissal depends on contractual or handbook-created entitlements)
Bissessur v. Ind. Univ. Bd. of Trs., 581 F.3d 599 (7th Cir. 2009) (plaintiff must plead the contract terms creating enforceable rights)
Hagan v. Quinn, 867 F.3d 816 (7th Cir. 2017) (usual practice is to dismiss state-law claims when federal claims are dismissed)
Pruitt v. Mote, 503 F.3d 647 (7th Cir. 2007) (standards for recruiting counsel in civil cases)