1992)). A reviewing court may reverse a university's decision to terminate an employee only if it finds a lack of substantial evidence to support that ruling. Harford v. University of Minnesota, 494 N.W.2d 903, 909 (Minn.App. 1993), pet. for rev. denied (Minn. Mar. 30, 1993).
Review by certiorari is limited to an inspection of the record of the administrative tribunal, and this court is confined to questions affecting the regularity of the proceedings and, as to the merits of the controversy, whether the determination was arbitrary, oppressive, unreasonable, fraudulent, made under an erroneous theory of law, or without any evidence to support it. * * * A reviewing court may reverse a university's decision * * * only if it finds a lack of substantial evidence to support that ruling. * * * Academic judgments are afforded great discretion, since decisions regarding a person's scholarship require expert evaluations that are not readily adapted to the procedural tools of judicial decision-making. Chronopoulos v. University of Minn., 520 N.W.2d 437, 441 (Minn.App. 1994) (citing Board of Curators of Univ. of Mo. v. Horowitz, 435 U.S. 78, 90, 98 S.Ct. 948, 955, 55 L.Ed.2d 124 (1978); Ganguli v. University of Minn., 512 N.W.2d 918, 921 (Minn.App. 1994); Harford v. University of Minnesota, 494 N.W.2d 903, 909 (Minn.App. 1993), review denied (Minn. Mar. 30, 1993)), review denied (Minn.
This court has previously held that the president's or regents' ability to reject the SJC panel's recommendations does not violate due process. Harford v. University of Minn., 494 N.W.2d 903, 909 (Minn.App. 1993), review denied (Minn. Mar. 30, 1993), overruled on other grounds, Shaw v. Board of Regents of the Univ. of Minn., 594 N.W.2d 187, 190 (Minn.App. 1999). II.
Even if appellants initially could have challenged the promotion by bringing a declaratory judgment action, having elected to challenge the promotion under the city's grievance procedure and pursue the grievance to a determinative conclusion, they cannot avoid application of the rule that certiorari is the exclusive method to obtain review of an administrative body's quasi-judicial decision by now bringing a declaratory judgment action in the district court. See Harford v. University of Minn., 494 N.W.2d 903, 906 (Minn.App. 1993) (Minnesota Supreme Court has consistently held that res judicata applies to administrative decisions when the agency acted in a quasi-judicial capacity), review denied (Minn. Mar. 30, 1993), implied overruling on other grounds recognized by Shaw v. Board of Regents, 594 N.W.2d 187 (Minn.App. 1999), review denied (Minn. July 28, 1999). Appellants argue that the employment rule authorizing only individual employees to pursue a grievance deprived appellants of the "opportunity to have their day in court."
May 9, 1996), that a former university employee's breach of contract claim should be initiated in district court. Similarly, in Harford v. Universityof Minnesota, 494 N.W.2d 903, 906 (Minn.App. 1993), review denied (Minn. Mar. 30, 1993), this court stated that the university lacked jurisdiction to decide a breach of employment contract claim and that, therefore, the claim was not barred from being brought in district court. As the university correctly observes, however, Zahavy and Harford were decided prior to the supreme court's decision in Willis.
Therefore, we can reverse the University's decision to terminate an employee only if we find a lack of substantial evidence to support that decision. Harford v. University of Minn., 494 N.W.2d 903, 909 (Minn.App. 1993), review denied (Minn. Mar. 30, 1993). I. Procedural and Substantive Due Process
The decision to grant or deny res judicata to a prior decision is a matter of judicial discretion. Harford v. University of Minn., 494 N.W.2d 903, 907 (Minn.App. 1993) (citation omitted), pet. for rev. denied (Minn. Mar. 30, 1993).
This court conducts de novo review of questions of law. Harford v. University of Minn., 494 N.W.2d 903, 906 (Minn.App. 1993), pet. for rev. denied (Minn. Mar. 30, 1993). Ringsred contends the common law collateral source rule protects and preserves his claim against the Co-op.
The procedures established for faculty tenure cases are more formal, and have been repeatedly upheld as consistent with due process concerns. See, e.g., Mueller v. Regents of Univ. of Minn., 855 F.2d 555, 558-59 (8th Cir. 1988); Agarwal v. Regents of Univ. of Minn., 788 F.2d 504, 508 (8th Cir. 1986); King, 774 F.2d at 228; Harford v. University of Minn., 494 N.W.2d 903, 909 (Minn.App. 1993), pet. for rev. denied (Minn. Mar. 30, 1993).
The University's own procedures, requiring review of Ganguli's tenure complaint by the "Judicial" Committee, are quasi-judicial in nature. Cf. Harford v. University of Minnesota, 494 N.W.2d 903, 906 (Minn.App. 1993) (University's grievance procedure was "arguably quasi-judicial in nature"), pet. for rev. denied (Minn. Mar. 30, 1993).