Although some criticism still remains [see, for example, AAUP (2006) 39-40], case law in the United States has continued to uphold the use of collegiality as a factor in making decisions regarding faculty employment, tenure, promotion, and termination. (See Mayberry v. Dees and University of Baltimore v. Iz.) Indeed, the lack of civility or collegiality can be used as a legitimate basis to terminate a full-time faculty member (Bresnick v. Manhattanville College, Stein v. Kent State University).