Lily Barrett v. Diana Williams

── Lily Barrett v. Diana Williams ── Court: Court of Appeals for the Eleventh Circuit Date: June 02, 2026 Category: NEW USCA11 Case: 24-12884 Document: 30-1 Date Filed: 06/02/2026 Page: 1 of 15 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-12884 ____________________ LILY BARRETT, Plaintiff-Appellant, versus DIANA WILLIAMS, LISA ECKEL, JENNIFER BUCHANAN, In their official and individual capacities, Defendants-Appellees, ____________________ Appeal from the United States District Court for the Northern District of Florida D.C. Docket No. 4:23-cv-00247-MW-MAF ____________________ Before ROSENBAUM, GRANT, and ABUDU, Circuit Judges. GRANT, Circuit Judge: USCA11 Case: 24-12884 Document: 30-1 Date Filed: 06/02/2026 Page: 2 of 15 2 Opinion of the Court 24-12884 Lily Barrett was working toward her doctorate in neuroscience at Florida State University when she hit a roadblock. Her main faculty sponsor, known as a “major professor,” was no longer willing to work with her, citing doubts about the quality of Barrett’s research, as well as reports of both protocol violations and interpersonal issues. University policy required that Barrett find another major professor to continue in the neuroscience program. So for five months, she reached out to other professors in the department—but no one would agree to work with her. Lacking a major professor, she chose to graduate with just a master’s degree. But graduation did not mark the end of Barrett’s dispute. Still smarting from her failure to find a new major professor and earn the Ph.D. she originally sought, Barrett sued about a month after graduating. She alleged violations of her procedural due process rights. The district court granted summary judgment to the defendants. We affirm because Barrett received adequate process. I. In August of 2019, Barrett began working toward a Ph.D. in neuroscience at Florida State University. Her major professor was Dr. Xiaobing Zhang, the faculty mentor who had sent her offer letter when she was first admitted to the program. And what is a major professor? The major professor, in conjunction with the student’s doctoral supervisory committee, determines whether the student’s work satisfies the University’s USCA11 Case: 24-12884 Document: 30-1 Date Filed: 06/02/2026 Page: 3 of 15 24-12884 Opinion of the Court 3 requirements. As Barrett put it, you’re “in their lab, you’re doing their research,” and they’re teaching you “how to be a good scientist.” Students must have a major professor to continue in the program, but they are not entitled to one—the student, the professor, and the program director must all consent to the arrangement. Normally, a student works with the same professor who invited them to the program; an applicant that no one wants to work with would typically get rejected. Still, if problems emerge after admission, either the student or the professor can end the relationship at any time. Barrett initially “really hit it off”