On the same day it rendered the Roth decision, the Supreme Court in the Sindermann case explained the circumstances that might create a legitimate expectation of reemployment for a nontenured teacher. Sindermann was a nontenured faculty member in his fourth year of teaching when he was notified, without a statement of reasons or an opportunity for a hearing, that his contract would not be renewed. He challenged the lack of procedural due process, alleging that nonrenewal deprived him of a property interest protected by the Fourteenth Amendment and violated his First Amendment right to freedom of speech.
In advancing a protected property right, Sindermann claimed that the college, which lacked a formal tenure system, had created an informal,
