What the Exxon Valdez Teaches Us About Higher Ed Right Now

Paul Liebman

I don’t think titles matter. I don’t care who I report to. I’ve reported to the president, Adele, I had a dotted line to Michael. I worked for David Koch of the Koch brothers. What I think the compliance community has been sold a bill of goods that if you become a compliance officer and you get all your certifications and whatever, you should report to the president. And you should have ongoing conversations with the president. What you should do is have access and influence. That’s what you should have. It doesn’t matter who you report to. The question is, if you do your job well enough, people will find you.

Scott D. Schneider

Hello and welcome to Campus Docket, a Volt podcast about the legal challenges reshaping higher education. I’m Scott Schneider, attorney and adjunct professor at the University of Texas School of Law. And I’m joined by Eric Kelderman, senior writer at the Chronicle of Higher Education. Each episode will unpack the key legal developments that matter to higher ed leaders, student rights, faculty contracts, the DEI lawsuits and government oversight.

Campus Docket is produced by Volt, the go-to news source for higher ed leaders and decision makers. Remember to visit Volt at voltedu.com and subscribe to Campus Docket on Apple Podcasts, Spotify, or wherever you get your podcasts to make sure you never miss an episode. Let’s get into this week’s show.

Eric Kelderman

Alright, we’re back. Campus Docket, Scott. The dude abides.

Scott D. Schneider

Yes?

Eric Kelderman

You’re very dude-like. I just think of you, if I were to compare you to a lot of folks, I would think of you as the dude.

Scott D. Schneider

Thank you. That’s literally, I’m sorry. That cracked me up. It’s literally my favorite movie. And I was doing some calls today where I was quoting, and I’m like, are you following me? Jesus, Kandana, man. I won’t do that for the audience, but what a great, perfect movie. On every level, it’s the most perfect movie.

Eric Kelderman 

I know. We’ll use movies as an icebreaker someday. And we’ll get into that. But we do have to do something serious here, which is we have to talk about really our newest legal development in the higher ed world. And this is, I think, a fascinating, fascinating topic. About a week or so ago, the Supreme Court handed down a decision on the emergency docket, basically saying that a group of litigants who were challenging the cancellation of NIH grants, which the government had decided to stop paying because they were related to, I guess, DEI stuff, that was the government’s assertion. A federal district court judge had halted those cancellations and the administration appealed on the emergency docket to the Supreme Court. And the Supreme Court said, basically, that the federal district court judge did not have the authority to halt those payments, that those payments have to be challenged in the US Court of Federal Claims, which is basically a branch of the judicial system that deals with breach of contract stuff with the government, and where challenges have to be made one at a time. They can’t be aggregated or brought into class action suit. You can’t consider constitutional issues at the Court of Federal Claims. It was a weird decision in a lot of ways, but they also said that the federal district court judge did have the authority, however, to overturn the government’s rationale for dismissing those grants. Raises so many issues, I think, in higher ed legal professional world. What’s your sort of top line takeaway from this?

Scott D. Schneider

My top line takeaway is all of those justices would have benefited from a legal writing class. It’s a painful read. I’ve read David Foster Wallace, and he was clearer. So if you read the decision, there’s concurring opinions, dissenting opinions. It’s basically Amy Coney Barrett from New Orleans, who did theater with my wife in New Orleans, by the way, who writes the controlling opinion. And I think you hit the nail on the head, it’s in assessing whether or not something is constitutional or violates the Administrative Procedures Act, the federal court has jurisdiction over that. In terms of who has authority to reinstate grant funds? It’s the Court of Federal Claims. I don’t know, I will say this, and we probably need to get an expert on who can talk about this. I’ve never litigated anything in those courts. I don’t know. I think you’re right about you can’t aggregate claims, but I’m not sure about that.

Eric Kelderman

I talked to someone from the Council on Governmental Relations, which is this is sort of their bailiwick, and a couple other folks I talked to for an article I did recently. That was what I was told from those legal professionals that you cannot aggregate claims, can’t bring class action, that they have to be challenged one at a time. Which would make a really, really difficult situation, for a place like Harvard, for instance, if that ends up being the route that their summary judgment argument goes, if their federal district court judge says that or if the Supreme Court weighs in on that.

Scott D. Schneider

Exactly. I mean, I don’t know what the exact count is on. I know that the monetary amount, my hunch is the number of grants is probably in hundreds at Harvard, maybe thousands, I don’t know, that have been frozen. 

Eric Kelderman 

Yeah.

Scott D. Schneider 

And yeah, I mean, the takeaway from that case is to have those grants reinstated, even if a court comes back and says, hey, this was unconstitutional. Hey, this violated the administrative procedures. I mean, you could obviously use that in support of your claim that these grants should be reinstated, but you have to go through a totally different process for it in a different court. I know one of the dissenting opinions, and I can’t remember who wrote it, pointed out what seems to be the inefficiency of that. And it is, but it also makes this a much more powerful tool for the federal government to use and to leverage an institution to enter into an agreement like Columbia entered into. 

Eric Kelderman

Right, exactly. I think the concern is it gives the executive branch really almost a blank check in saying, we want you to do this and if you don’t do this thing, we’re going to cancel your federal grants. I think that’s a concern that that’s going to be the outcome here. And in Harvard’s case, they’re arguing that because they didn’t comply with this April letter from the administration, that the government canceled their grants in retaliation. And if that’s the case, if it’s not really a breach of contract issue, then what can’t the executive branch demand of an institution at that point?

Scott D. Schneider

Yeah, I think you’re hitting on the concern about this path the Trump administration has embarked on, coupled with the Supreme Court’s decision.

Eric Kelderman

A couple of interesting things to me about this, which is the court seems to have set legal precedent in an emergency docket ruling on a case that they did not hear. They weren’t fully briefed on it as far as I know. They didn’t hear arguments. It was just something that came out of the so-called shadow docket. I’m not a constitutional law expert, obviously, but that seems notable to me that the court is setting precedent in these emergency docket rulings.

Scott D. Schneider 

Yeah, no, if I recall correctly, I’d have to look at what Justice Barrett wrote, but she was relying on one case in particular. Yeah, but this is now a precedent that will certainly be cited in the Harvard summary judgment. I know, I think you went and watched those arguments. Did this argument come up there?

Eric Kelderman 

Yeah. Yeah, I was in Boston for the summary judgment hearing.

Scott D. Schneider

Yeah, no, it’s an interesting approach by the administration, historically unprecedented. And I think the takeaway is that the challenges to the revocation of funds is going to prove to be even more challenging than we thought it was initially. 

Eric Kelderman 

Yeah, even harder, right?

Scott D. Schneider

Yep.

Eric Kelderman

Well, let’s get into it.

Scott D. Schneider 

Sounds good.

Eric Kelderman 

Well, hey, today we’re going to welcome Paul Liebman. His title is Executive Director of University Compliance Services and Chief Compliance Officer at Vanderbilt University. Welcome to Campus Docket, Paul. 

Paul Liebman

Thank you.

Eric Kelderman 

And we should note, of course, that despite the fact that Paul is wearing a Vanderbilt hat and sitting in his office at Vanderbilt as we speak, he is not speaking on behalf of the university at this point. He’s just speaking from the university.

Paul Liebman

Correct.

Eric Kelderman 

Yeah, good.

Scott D. Schneider 

Very cool. He’s also, I don’t know if you know this, but he’s like a Divinity School student.

Paul Liebman

I am.

Eric Kelderman

Yeah, we’re going to talk a little bit about his background. So I’m looking forward to that discussion.

Paul Liebman

I’ll just stay up front. Everything I say is, again, doesn’t reflect the policies of the university. It reflects my opinions based on my career path.

Eric Kelderman

Sure, absolutely. That’s good. Well, as you know, Paul, we like to start our conversation with our guests with a little bit of an icebreaker. And I’m actually going to probe a tension point between you and Scott, because I know you guys know each other. And I’m going to ask, which city is your favorite music city in the world?

Paul Liebman

Well, from my perspective, having lived in both Austin and Nashville, I think I’m in the better position to tell you that Nashville, with the title Music City, is the place to be. In addition to, obviously, all the country, we have just innumerable amounts of locations to listen to the blues, listen to rock music. We have an unbelievable symphony here. It’s just a tremendous place to listen to music.

Eric Kelderman

Scott?

Scott D. Schneider

When you have really bad taste in music, your opinion about these things shouldn’t matter. Yeah, there’s no better. There’s a couple of cities that are close, but there’s no better live music scene in Austin. And I’ll be taking advantage of that later. Yeah, that’s easy. That’s not even a complicated question.

Paul Liebman

Yeah, well, you’ve been wrong on lots of things and you’re wrong on this one, so that’s fine.

Scott D. Schneider

I can’t think of many things I’ve been wrong about, but it’s another conversation for another day.

Paul Liebman

Correct. And to move this along, rather than agree with you and both of us be wrong, we should probably just move.

Eric Kelderman

Well, I’ll just tell you, I’ve seen live music in New Orleans and Austin, and I think it really depends, and Nashville, by the way, I’ve been down on Broadway, been to a couple of great honky tonks on Broadway in Nashville. I’ve been on East 6th Street, right, in Austin, and I’ve been to several of the jazz spots in New Orleans, I have degrees in music. I would have to say the best live performances I’ve seen have been in, none of those places. I heard the Branford Marsalis Trio at the University of Maryland a few years ago, which was really just mind-blowingly good. I heard Isaac Stern play violin in Prague, in the Czech Republic, probably the best classical music concert I’ve heard in my life. And so those are both up there. Of course, lots of great stuff in all of those places.

Scott D. Schneider

Hey, can I talk about Branford Marcellus for a second?

Eric Kelderman

Yes, go ahead, yeah.

Scott D. Schneider

Because I know him and I also see you got the Van Halen album.

Eric Kelderman

I got the Van Halen album in the background there. Yep.

Scott D. Schneider

It’s one of my favorites. Yeah, so my uncle was a big band director in high school at Dillsow High School, Go Cavaliers in New Orleans. And one of his students, who I got to be friends with when I was very young, was Branford Marcellus. So there, in your face.

Paul Liebman

There you go.

Eric Kelderman

Wow. I mean, amazing, amazing trio, amazing musician. I’ve heard Wynton and Branford and Delfeayo, and Ellis. I heard Ellis the first time I was in New Orleans. 

Scott D. Schneider

Snug Harbor.

Eric Kelderman

I went to Snug Harbor and heard him play in a trio and it was amazing. 

Scott D. Schneider

There you go.

Eric Kelderman

Yeah. And they have another brother who plays drums. I heard him at Preservation Hall on one of my trips.

Scott D. Schneider

Was that Jason? 

Eric Kelderman

Yeah, it could be. There’re a lot of them.

Scott D. Schneider

Yeah. That’s a great crew.

Eric Kelderman

But I’ve heard it a couple of times, so that’s awesome too.

Scott D. Schneider

Yeah, Wynton is not as much fun. That was my recollection. He was a very serious man.

Eric Kelderman

Yeah, yeah, but also a phenomenal, phenomenal musician, really amazing talent. 

Scott D. Schneider 

Without a question.

Eric Kelderman

So let’s get into it. Paul, your title is, you do compliance. 

Paul Liebman 

Yeah.

Eric Kelderman

A lot of folks think about becoming a lawyer growing up. I don’t think a lot of folks think about becoming a compliance officer. So tell me, tell us how you got into this role. What drew you to this? Tell us about your background.

Paul Liebman 

Do you want the short version or the long version? How much time do we have? I’ll tell you, when I was in law school, I realized very quickly I wasn’t as competitive as everyone. And so I went out and got a job. I had a political science Soviet studies minor. That tells you how long ago I was in school. And so I realized if I was going to get a job after law school, I was going to have to do things outside of the classroom. I went and got a job working for a foundation that resettled Soviet defectors. just shuffled people around. These were high level government defectors. They would come over and the State Department would suck them dry from their information. And then I would drive them around, help them find jobs that weren’t washing dishes or driving taxis. I would go shopping with them, help them find apartments. That was my job. The General Counsel at that foundation was a significant lawyer in DC. He was a FERC lawyer. And he came to me and said, would you like to make some money? I need a clerk. And so I went to work for this firm, Van Ness Feldman. The moment I put that on my resume, every oil company in America contacted me. They couldn’t believe those, this dumbass out there in law school that had any interest in natural gas law, which I did not. And so I got invited to spend a summer, my summer associate job in my second year. And that led to a job offer. When I started, I was assigned to the environmental litigation group. I started two months after Valdez. And so everybody who was an environmental lawyer and could spell Exxon, went to the special project Valdez and I got what was left, which was a lot of underground storage tank cases and stigma cases and gas station and terminal cases. In my docket, it went from about 40 cases to a thousand in about a year. So really all I did was I flew around with outside counsel managing all these cases. I literally did not even have my license yet. I hadn’t passed the bar yet. So I did that for a while. I got transferred to be a refinery attorney. Apparently I pissed somebody off at Exxon and they sent me to Newark, New Jersey. 

Scott D. Schneider

I find that hard to believe, by the way.

Paul Liebman 

Oh, yeah, you know me well enough to know that I piss people off. But yeah, so I became the environmental compliance attorney for John D. Rockefeller’s first and oldest refinery in Lyndon, New Jersey. And that’s where I really started just focusing on compliance. And I was a compliance lawyer. I eventually made my way out of Exxon. It wasn’t a tremendous fit. I had a sense of humor. They did not. And so I ended up in Minnesota where my wife is from and did some work for Koch Industries. They had a couple of refineries, one in Texas and one in Minnesota. And they brought us down to Wichita. When I got to Wichita working for Koch Industries, I was doing compliance for lots of things and doing compliance due diligence on the hundreds of deals they were looking at at any given time. And then I went with one of the deals and became the compliance attorney for this large multinational. And that was my first real full-time compliance, not just environmental, but everything. That job begat Dell. I went to work for Dell. I was the global compliance counsel for Dell. I had the pleasure of building a compliance program while the DOJ was instituting criminal action against Michael Dell for accounting errors. And I was in one cube, DOJ was in the cube next to me. And I had a lot of fun building out their global program, did that for a couple of years. I sort of got burnt out with that. Had a consultancy on the side. I went to work and did some work for a number of companies, the biggest of which was Cisco Foods. I helped build out their global program. 

And then in 2013, my friend at the University of Texas called me and said he was leaving to go to the University of Miami and president Powers wanted to meet me. And I said, I have this amazing gig going on right now and making a lot of money and I’m really not interested. And he said, you need to come talk to president Powers. Well, you may know Powers by virtue of the Powers Report, which was, he was the Dean of the law school at the University of Texas. And he was hired by the Senate to figure out what went wrong at Enron. And so the Powers Report was this 5,000 page report. So I said to myself, this is the guy who, sort of like the Pope. I mean, I wanted to go meet the Pope. He created my profession. Compliance officers didn’t exist really in any meaningful way before Enron and before Sarbanes-Oxley, right? And so I went to meet him and we just hit it off. Literally before I left that office, he was shaking hands on a deal. He said something that was very profound to me that I think many of your listeners will understand. You know, he told me after the career it had to that point, especially things like Dell with, you know, 100,000 employees, 20 different languages, 150 countries. Think how easy it was going to be to be at the University of Texas with just 20,000 people all speaking English. How easy is this going to be for you? And as you might imagine, that was a complete total lie.

Eric Kelderman 

Yes.

Paul Liebman

Because the University of Texas is a global brand just like Dell. And every single issue that Dell had, University of Texas had, plus higher education, right? 

Eric Kelderman

Absolutely.

Paul Liebman

And we had your most significant employees don’t think they’re employees. So like they’d be the equivalent of your top salesman in a company, the faculty, they literally don’t believe that they’re staff. In fact, we actually refer to them staff and faculty, right? As if they’re not staff somehow, they’re not employees. So I did that for a number of years. I got completely burnt out. After about five, six years, there was a lot of political pressure between the governor’s office and president Powers. He ultimately resigned. And I worked for a couple more years and my dad was ill and I ended up taking a leave and was going to take some time off and then my dad told me I was an idiot. He was dying, but he said, I can’t believe I raised somebody who would quit their job to be with me. So go find some work. And so I went back to Texas and I got hired by Baylor, in my corporate clergy consultancy in the wake of their Title IX problems. The Big 12 was withholding money and they wouldn’t give them the money until they could prove they had a guesting class compliance program. So I was hired as a consultant to build that program out for them. Was there for about a couple months and president Livingstone, who’s a marvelous human being, by the way, said to me, should come in and be our chief compliance officer. You should just come and be an employee, which was fascinating to me because it’s a school that only hires Christians and I’m a Jew. So I became the only Jew in the entirety of Baylor University. And it was a great experience. They are wonderful people. And I enjoyed it. About six months in, my father died and I decided I was going to take some time off. I transitioned somebody into the job. And I went to work, moved back to Austin and took a job selling dog food at a feed store for $12 an hour. One of the great jobs of my life, probably the best job of my life. And I would have gladly done that forever. 

And then I got the fateful call from Harvard. So Harvard, see if you can sense the path that occurs here. They called me and said, we have a little problem. We have a chemistry professor who is under indictment for selling secrets to the Chinese and we need help building out a compliance program for foreign influence. And I said, I don’t know anything about foreign influence, really. You know, it wasn’t a big issue for me when I was at Texas or at Baylor, honestly. They said, no, we don’t care about that. We have that. What we need is the compliance program building. That’s what we really need. So I did that. And after about six months, came to me and said, you know, we really like you to be the chief risk and compliance officer for the university. How does that sound? I guess they call it the institutional risk and compliance. They didn’t use the word chief there. So I took that job, moved up to Massachusetts, did not enjoy the environment. Once again, not a place with a sense of humor, probably less so now than even then. But sort of got them on the path and then the job at Vanderbilt opened up and my daughter had gone to school here. I love Nashville and really loved my meeting with my general counsel and made the move down here.

Eric Kelderman

What it sounds like to me, Paul, is you have a hard time holding down a job.

Paul Liebman

You know, it’s funny because that’s exactly what my kids went. When they asked my kids, what does your dad do? They say he gets jobs. He does for a living. He gets jobs. I have this weird idea. I don’t know how people could do my job in the last 15, 20 years.

Eric Kelderman

Why is that? What about the job makes it so tough?

Paul Liebman

Well, I think if you’re doing your job well, you’re having really direct and blunt conversations about with people. And at first, it’s easy. There’s a lot of low hanging fruit at first. And everybody’s like, that’s a great idea. We should have like a policy office. Let’s build a policy office or, you know, we could really use training. How are we going to coordinate all the training on all these topics or all these employees? And those are easy. Believe it or not, those are actually easy things to do. But then at some point, somebody brings you a question and you’re honest with people and you have this honest conversation and you say, you know, I’m really, you know, I don’t think I want to go in that direction. You have the right to make whatever decision you want. That’s what you get paid for is to manage things. And but I don’t really, it’s not fun for me anymore. I like the building and the fixing and that’s really, that’s really all I do.

I joke all the time. I’ve used this in interviews many times. I’m really not very good at many things. I have limited intellectual skills and diminishing operational skills as I get older. But I know there are three things I do really, really well, true in and large honesty. I’m a great dad. I love my kids and my dad is my number one job. I’m a freakishly good parallel parker for some reason. I don’t know why. I have terrible eyesight, you know, it’s sort of like a Mr. Miyagi thing where I, for whatever reason, I’m really good at parallel parking. And the last thing I do is I’m really good at building programs. Like I can take like lots of disparate pieces. And because I’ve spent my life watching cartoons, I can simplify things and really bring lots of disparate pieces together and build things.

Eric Kelderman

And what does it mean to build a compliance program exactly? Because we’re talking about, right, there’s laws, right, Title IX, Title VI, right, the Higher Ed Act, and there’s regulations, hundreds, thousands of them, and you have to figure out how the university will meet all those statutory and regulatory requirements. So how do you build a, I guess, how do you build a compliance program? What does that actually mean?

Paul Liebman

So there’s certainly a lot of guidance out there of what an effective compliance program means. The federal sentencing guidelines in effect define what an effective program is. You’ll have a total at the top. You’ll have standards and policies. You’ll have controls and training and some sort of monitoring and audit. You’ll have discipline and corrective action to make sure things don’t reoccur. And it’s like a big loop that you’re working on all those sort of the seven elements. I don’t strictly follow the sentencing guidelines. They were never designed when they were written. They weren’t designed to do what we’re doing. Again, to put things in perspective, I started being a compliance officer before the sentencing guidelines actually sort of took effect after Sarbanes-Oxley and Enron. 

But the idea is, for me, what I do when I get to a place is I spend probably the first six to eight months, largely, just going out and figuring out what do we do? What are the operations and activities? So I get a sense of what it is we’re doing and where and who’s doing them. Generally speaking, most universities have between 40 and 50 compliance areas, labor and employment, environmental health and safety, athletics, research, typical ones you guys deal with on a regular basis. So I figure out who’s doing what. I create a matrix of the areas and the significant laws, who’s on the front lines, who’s in the chain of command, who’s the ultimate executive owner. And I just go and have conversations. I like to, I’ve said this many times, it’s the most important thing people can understand, the two most important things people can understand probably are one, when you get any place and you’re new, the most important thing is to make small deposits in the credibility bank in your organization. So you go around and meet people when there’s nothing at stake and you talk about it just in human terms, you tell me what you do, and how could we be of help, and what services can we provide? The second thing I always do, I tell people and this one really this is why I don’t get invited to conferences anymore.

Scott D. Schneider 

Congratulations on that.

Paul Liebman

Yeah, absolutely. I don’t think titles matter. I don’t care who I report to. I’ve reported to the president, Adele, I had a dotted line to Michael. I worked for David Koch of the Koch brothers. What I think the compliance community has been sold a bill of goods that if you become a compliance officer and you get all your certifications and whatever, you should report to the president. And you should have ongoing conversations with the president. What you should do is have access and influence. That’s what you should have. It doesn’t matter who you report to. The question is, if you do your job well enough, people will find you. And you’ll have access. If you’re not a flamethrower, if you’re not making every issue like it’s the existential issue, you’ll have influence and you can have real conversations and that sort of builds on it. In many places, it’s better not to be reporting the president. At Texas, you know, I used to joke, if the president’s office is the sun, right, I don’t want to live on Mercury. It’s really hot on Mercury. I don’t know if you know that. Like, Earth is nice. You can breathe, takes a long time to get there, right? My mindset is I want to be separated enough so that I can go do what I want to do and not have this constant reporting obligation.

Eric Kelderman 

I’m going to jump in here. Scott, you work with a range of clients. You obviously interact with issues around compliance. Some of them have compliance officers. Sometimes you become the client, the compliance officer, I think, in your work. I’d like to hear, sort of, when you go to a place, is it obvious to you that the compliance function either works or doesn’t work right away? And what are usually the hallmarks of a good program that you see?

Scott D. Schneider

Yeah, I think it’s, I’m gonna throw this out to Paulie as well. Can I call you Paulie?

Paul Liebman

You can.

Scott D. Schneider 

I think it’s, when I think of good compliance programs within universities, and then I’m going to ask you some questions.

Paul Liebman 

Sure.

Scott D. Schneider

I think of, you know, they’re the kind of check-the-box technical legal stuff, is, higher ed as an industry. I think people don’t realize this is probably the most regulated industry in the

entire American economy, both from civil rights, you know, the Clery, the research compliance obligation. So it’s, hey, do they have the kind of check-the-box compliance pieces? And then I start thinking of the big picture. Is this a place which ensures that people in the community don’t get hurt, right, on the front end, and when they do fix it, come up with a plan to minimize the risk of it happening again. And then there’s this second or third piece, is protecting the financial resources of the institution, avoiding both fines, penalties from all the regulators, avoiding enormous lawsuits. It’s kind of the check-the-box stuff, and then you look at the infrastructure, is there sufficient infrastructure given all the regulatory obligations? But is it, hey, we minimize the risk when people get hurt, people in our community get hurt, that that’s sort of a rare event. And when it does, we have the DNA to get together, fix it, policies, processes, people, reorganizing things to make sure it doesn’t happen again. And then that last piece is to me about avoiding liability. And it’s on that, I want to riff on those for a few with you because I think these are really top of mind. And so I’m going to make a sarcastic point. We had a shooting, another school shooting or church shooting. And, you know, you go back to the school shooting. I’m forgetting, was it out in Virginia Tech, many years ago. What was it? A decade, two decades ago. It’s been a while.

Eric Kelderman

A decade ago. Probably 12 years ago.

Scott D. Schneider

Look, when I was at Tulane, when I was in-house, you know, that was something we thought about all the time. I mean, and we had these extensive behavioral intervention team groups. We had students who were consistently, and people in the community who were consistently on our radar. I mean, it took years off of my life to do that work. And I think post Virginia Tech, I mean, there were all these expectations on Virginia Tech and they then really studied it and were real candid about where they failed and bridge the gaps, make sure that this would never happen again. And you kind of pivot to the moment. And I’m not trying to be overtly political, but I can’t imagine anyone at Virginia Tech, who would just come out and say the way we’re going to address this is, hey, thoughts and prayers. And so it’s a long way of saying it’s like the expectations for universities and institutions to prevent, which are like these deep-seated cultural issues, especially in some communities, is remarkable. When I think of really good risk management and compliance programs, it’s like we’re in these communities, And at some level, the expectation is, and it’s completely unrealistic, there’s this bubble over it. I was in New Orleans, you know, you were in Nashville, you were here in Austin. And the expectations for institutions seem completely outsized when compared to state government, local government, certainly the federal government. Thoughts on that?

Paul Liebman

Wow, lots of thoughts. So I’m going to do two tracks. The first track is an understanding when I go do risk assessment. So I’ll do an annual risk assessment either as part of the enterprise risk assessment process or my own. I’ll either tag along, but we have a formal enterprise risk assessment. My questions don’t look at like anything the other people are doing. My questions, we have a group at most universities of 200, 300 people where we’ll ask questions. My questions are designed around, are there any behaviors or activities or practices which you think could create significant liability for the university and your current job? So we’re talking to people who are subject matter experts in whatever field they are. We’re talking faculty, we’re talking people who run administrative units. Then I tell them what I think “significant” means. And although you can say that there’s no real order to the kinds of liabilities, there really is. Death or serious injury to people is number one. I want to know if there’s anything happening on our campus. Just as a human being, do you worry about when you walk from your parking garage to your office? It may have nothing to do with the job that they do, but we have 300 people all over campus. That is a diagonal slice throughout the organization. And I’m trying to figure out anything that could cause death or serious injury, you know, whether it’s job related in the lab, involving kids, or just, again, just matriculating, walking around campus, right? 

The second thing is criminal liability. Is there anything, these people are theoretically experts in their field. So what I’m doing is I have a general knowledge of what the laws are. I’m not a lawyer. I don’t act as a lawyer and haven’t acted as a lawyer, but I can engage them in conversation. And we talk about things that are not just, you know, very specific criminal issues. We talk about things that bring criminal liability, lying to the government, right? Is the easiest way for the government to bring criminal action against you and open up an investigation. And so we talk about what do you do to make sure that when you’re communicating with the government, everything is truthful, accurate, complete. Tell me your process. So we’re having that conversation. We talk about material financial liability. We talk about business interruption, business loss, the activities that we’re doing that might interrupt our strategic objectives. We’ve invested incredible amounts of money into something and to have it shut down even temporarily or permanently. And we go down that list and that’s sort of how we figure out what the compliance areas, then we prioritize and say, okay, you know, we’ll have hundreds of responses, generally. And we figure out, okay, these are the common themes we’re seeing. These are the things we should be working on. Now, how do we go about building a program around that. The compliance officer, it’s important to understand, there’s sort of a holy trinity between compliance, legal, and audit, right?

Scott D. Schneider

Did you learn about this at Baylor?

Paul Liebman

Yes, indeed. I learned about it in prayers before meetings. Legal tells us what the law is. They’re the what. They tell us what, okay? We’re all assurance functions. So generally speaking, you’re engaging lawyers, either internal or external, to say, okay, do we have a problem here? Are we out of compliance with something? Then they come to me, and I’m sort of like the pep voice. I’m tools, parts, and services. That’s really what I am. And so somebody will bring something to me and I’ll say, okay, this is the standard, either the law or the regulation. And how do we get there? What should the policy look like? What should our training look like? What kind of controls, human, operational, what kind of controls should we put in place? And then audit comes in at the back end and says, the controls you designed, designed to be effective and are they operating as designed? And it’s this constant little dance between the three assurance functions. And that’s really how it works in the real world. And it’s really important from my, it’s been my experience, very important that people stay in their swim lanes. I’m a lawyer, I could give legal advice. But there are people who literally, like Scott, who spend their days thinking about the law, the actual law. That’s not me. That’s just not me. So I will rely on his advice and build around that advice. And we’ll have queries about what is the extent, what does compliance really mean? Because compliance is sort of a continuum. And it all depends on how much money you want to spend, really, to feel assured that you’re not going to have a problem. 

The second thing I want to talk about is when you talk about the shootings, it’s really interesting. We had a murder on our campus at the University of Texas in 2015. We had a homeless person, who wandered onto campus and bludgeoned a woman and raped her. And it was the first murder on the campus since 1966, which is really unbelievable since the tower shooter. If you think of the University of Texas at Austin and where it’s located, and what’s happening to the city. And it borders on Highway 35, which has homeless people encamped. It was sort of shocking that it hadn’t happened. We had lots of security and police officers. But you know what? A person wandered on at nine o’clock at night, and that’s what happened. And when that happened, the world collapsed on us and the president tapped me to create a plan to respond to it. And we spent millions of dollars, literally millions, thinking about lighting and pathways and video cameras around buildings and trauma kits at buildings, combining landscape and lighting to make sure that lighting was effective. We used drones to watch how people got on and off campus all day and at night. Our use of safety apps, our relationship with both the UT PD and the Austin PD, incredible amounts of effort, millions of dollars, and all we heard from parents, what an unsafe place the University of Texas at Austin is, right? And what I would tell people and eventually I think the president started telling people is that parents need to understand something. When you send your kid to the University of Texas at Austin, you’re sending them to Austin, Texas. So, whether it’s the West Campus area or 6th Street or wherever. It is a dangerous place. It is a major metropolitan area. That’s number one. 

Number two. The campus is absolutely the safest place in Austin, Texas. There’s nothing even close. We have police wandering, the 40 acres there, police wandering around all the time. It is, it is without a doubt. And then the third thing is, and this has to be true, you have to be committed to being better. Constantly checking yourself, where are their vulnerabilities. And we used to have vulnerability assessments. Poking at ourselves, trying to find the problems so that you get better from year to year. And it’s the same anywhere. In most places, the campus is the safest place, but they’re not immune to the things that when the city of Austin goes from 400,000 people to like a million and a half in 10 years and becomes the 10th largest city in America, it comes with things like that.

But it’s literally no different than any other compliance problem. Campus safety is one of the areas I work with, and everywhere. And I spend a lot of time really trying to have conversations about what makes a safe campus. I spent a lot of time walking. Every place I’ve ever been, I walk the campus. I come to campus every day. I bike the campus every day. I’m here in the morning. I walk it at night. There’s lots of people that do that, so that we can make sure that our compliance efforts are up to snuff.

Scott D. Schneider

Let me say this, I mean, you’ve seen this for 20 years and it’s ubiquitous, which is this criticism of higher ed and, there’s so much administrative bloat that isn’t tied to the core educational enterprise. But that’s because the expectations for institutions of higher education are much more exacting than any place else in the surrounding community. And this is an example. I mean, like you, Paulie, when I’m in Tulane in New Orleans, I mean, we would literally, in doing safety assessments, we would take a night and go, what are the most frequently foot trafficked places from off campus to our campus? Are they well lit? And then working, it was all of that sort of stuff. And that takes a lot of, it takes a lot of people to do it, to do it right. 

Can I transition a little bit because you mentioned sort of avoiding liability and avoiding those kind of compliance hits that pose an existential threat to an institution. And I’m watching this play out, we’re all watching this play out in real time right now. I’m not asking you to get political, but at Columbia, for instance. We saw the Trump administration come in, freeze, I don’t remember what the exact amount was, but a considerable amount of grant funding. 

Eric Kelderman

$400 million.

Scott D. Schneider 

Yeah. And then ultimately Columbia basically saying, hey, we’ll pay you, what to me remains an absolutely staggering figure over $200 million to resolve those things, which would bankrupt or if not bankrupt, cripple the vast majority of institutions of higher education. There’ve been rumors, I’m skeptical that Harvard’s about to pony up half a billion dollars. I mean, how do we get to this point? Does it demand that institutions rethink compliance in this space? Because most institutions can’t be in the business of sending out, at Brown it was $50 million, those sorts of checks. And then what does that look like? Do we have to, as a risk management measure, start rethinking our relationship with the federal government? Are we too dependent on the federal government, such that they can exert this sort of pressure?

And the other piece, and I bring this up a lot, and I try to navigate with a lot of, I’m Gen X, I’m not super political. My politics are boring. I loathe the culture wars. I find it to be tedious and boring. But is it a fair critique also at the back end that universities got so lumped in with one political party that, hey, this is only fair in love and war, that now there’s another party we’re going to penalize. It’s that jumble of thoughts. Like in the moment we’re in, does it rethink the way we have to conceive of risk management?

Paul Liebman

So I’ll say something that I started with. I don’t speak on behalf of the university.

Scott D. Schneider 

I understand.

Paul Liebman

Or the chancellor who I adore and my general counsel who I adore. 

Scott D. Schneider 

Great people.

Paul Liebman 

Great people. Those are issues outside of my swim lane. There’s lots of ways to be in compliance. Again, they’re making big decisions, existential decisions, and that’s what they get paid for. And when it comes time, when they make those decisions, whether it’s here or Texas or Harvard, wherever, they’re making decisions that are based on their strategic objectives. And it’s not my role. It just isn’t my role to have an opinion on that, an official opinion. My job is when they make a decision, how are we going to operationalize that decision? That’s it. 

But I do want to say something. This comes from the wisdom of being really old. And you’ll be where I am in about 10 years, Scott. 

Scott D. Schneider

How old are you? Okay.

Paul Liebman

I’m 62. 

Scott D. Schneider

Okay.

Paul Liebman

I’ve retired once. I came out of retirement because I just enjoy solving problems. I like building things. Again, I’m a little kid at heart. I like building things. If I could have little toy trucks on my desk, I would. I do have lots of toys in my office.

I want to say something that’s going to put in perspective how old I am. And I will get to your point in a minute. When I decided I was going to enroll in Divinity School and go for my master’s, I had to go get my transcripts at my previous schools. And I went to law school at George Washington University. When I called, they sent me to this woman, who I said I need a copy of my transcript for the Divinity School. And she said to me, oh, no problem. What was your email address when you were in School? And I said, email didn’t exist when I was in law school. She said, really? I said, yeah, email didn’t exist. And so we’re going to have to find another way. The conversation, that was like a 15 second delay on her end, she’s like, wow, email didn’t exist. That’s how old I am. The reason I say that is every single job I’ve had has had an existential crisis. At Exxon, I started after Valdez. At Dell, we were in the throes of the DOJ trying to, the DOJ’s position was that Michael Dell, they would settle, but Michael Dell had to agree to never be a CEO of a publicly traded company again, okay? That was the negotiating, that was what was going on. When I went to work for Koch Industries, Charles Koch had had an epiphany and decided that they were gonna be the most compliant company in America. They call it the 10,000% rule, 100% compliant, 100% of the time. That is not how they had operated. So it was literally a 180 flip from how they had operated. And so, in the middle of the Clinton administration, so Texas was literally caught between the governor’s office and the university. Every single place I’ve been has had an existential crisis of some sort. It’s the norm. It literally is the norm. It seems terrible and it is terrible. And people are trying to figure the way out and it may in fact be different. But from my perspective, the people who get paid the money are qualified and responsible for making decisions about the path forward. And my job and working with the lawyers to figure out what does compliance mean to them. And then they come to me and I can build anything from what they give.

Eric Kelderman

I want to dig into this just a little bit because there must be some challenge for you in terms of, we had the Obama administration with a certain focus on Title IX, right? That was a big deal.

Paul Liebman 

Title IX. I was the Title IX officer twice, interim Title IX officer at UT, 2013 to 2017.

Eric Kelderman 

And also on Title IV compliance.

Paul Liebman 

But by the way, that’s how I met Scott. He came and spoke. He was the guest speaker at our Title IX. 

Eric Kelderman 

And then we shifted. We had a big shift in compliance focus under the first Trump administration, right? And then the seesaw goes the other way again, we had the Biden administration, and now we have Trump 2.0. A lot of shifting focus, what does that mean for your job when you have this sort of roller coaster, as it were, of compliance obligations?

Paul Liebman

From my perspective, rather than concentrate on the law, which is important, I’m more interested in the behaviors of people on our campus, preventing death or serious injury, criminal liability, so forth. I’ll tell you the story, when I was working for Baylor. I was at a regents meeting and one of the regents, they were very nice people, but one of them said, you know, in the end, it appeared that we’d never even violated Title IX. We’ve gone through all these problems, and we probably had a good argument that we actually never violated Title IX. And I said to the gentleman, let me ask you something. You had a football coach, who was recruiting these folks from other universities who, it appears, factually, were raping students, female students, and no investigations were occurring. What difference does the law make? Is that really, if there was no law whatsoever, would that be acceptable behavior or not? And so the issue is let’s fix that behavior, right? The other stuff is sort of on the fringes. And again, it does go, it oscillates back and forth. But we shouldn’t lose sight of the real issue, which is the thrust of Title IX is to protect people. It’s to make it safe for people, so that it’s a good learning environment. The worst kind of discrimination is assault, based on sex. And so, to me, wherever these issues lie, I try to focus on what is the activity behavior that we’re trying to mitigate or prevent? And how do we build our program around what you think is, talking to the leaders, what you think is the appropriate response?

Eric Kelderman

And what do you do when, for instance, the behavior that an administration, a government expects you to prevent is one that, maybe, is not a real threat to the campus. I’ll give you an example, The transgender athletes thing, As far as I know, there is no example of a male to female transgender athlete assaulting one of their teammates. There’s a very small number of transgender athletes that play intercollegiate sports. I think that the president of the NCAA mentioned maybe a number of around 10, or 20, whatever it is, but it’s tiny compared to the population of athletes. And yet, we have an administration that is focused, laser focused on making sure that those people do not participate in intercollegiate athletics or are not in contact, I guess, with cisgender females in any regard, really. So the expectation there, the question is, is that really a threat to the population? Is there an actual threat there that you should be preventing? It seems to me like the definition of the law is somewhat flexible right now, and I wonder how that impacts you.

Paul Liebman

I think it’s always going to be flexible. It’s always going to oscillate. It’s probably more knee-jerk now than it ever has been. But in the end, the people who run the university, who are dealing with these billion-dollar enterprises, are making strategic decisions. And there’s an expectation that they’re doing what’s in the best interest of the university. And if that’s an issue they want to fight, they can fight it and I can help build around that. If they decide that’s not, it’s just not worth fighting over because we have lots of other issues that are equally important. That’s okay too. Again, my job, everywhere, I don’t get paid to manage a university. But my job is to make sure that once decisions are made, how do we go about making sure that our policies are the right policies? Making sure that we have the right kind of education, whether it’s a general awareness, heightened awareness, maximum awareness. How do we make sure we have the right controls? That’s my job. My job is to make sure that we are built out, so that the university’s leadership’s objectives are further.

Eric Kelderman

Scott, must have thoughts on this.

Scott D. Schneider

Yeah, no, it’s a tough one. The Chronicle had this piece recently about, was it Derek Bok at Harvard 30 years ago? Did you see this, Eric?

Eric Kelderman 

Oh boy, you know, that’s a good question. I don’t remember seeing the piece on Derek Bok.

Scott D. Schneider

Yeah, so he’s a very interesting player in the history of higher ed. I think as he was leaving Harvard in the 90s, he wrote this as a lengthy piece. I can send you the PDF. Maybe we’d post it to the show notes. Where he talks about the long-term risks to Harvard and it feels very prescient 35 years later. And the way he framed the risks, was not, I like what Paulie is saying, it wasn’t like we must comply with Title IX or Title VI and all that. It’s in terms of knowing institutionally what our values are and what we are and what we’re going to have to say no to in guiding our decisions by virtue of our values. And in his mind, it was independence, academic independence, creating a space where everyone felt comfortable sharing opinions and conversations, not getting overly political. He was worried about the corporatization of universities and their ties to businesses and even the federal government. And it was a really interesting thought piece and I’ll again, very long, really thoughtful, but it felt very prescient. And it’s had me thinking, this is almost what the moment calls for, which is, we do everything at universities and maybe it’s a matter of going, what are our values? What is the business we’re in? What is our mission? What are our values? What could compromise those values, whether it’s relationships with business, getting overtly political, relationship with the government, and what are certain red lines that we’re not going to be willing to cross? And I’ve talked about this recently in a meeting with some university presidents, and I would say, rethinking, well, at least having a line of risk management that is focused on mission risk management. These are our values. Are we deviating from them? And so, that’s one of the interesting things about higher ed over the last 20, 30 years. And I’ve seen it in real time. Is this rise of influence with lawyers. How at UT, for instance, the new president, Jim Davis, was general counsel. It gives you an example. And that’s certainly not uncommon, and Jim’s a really great guy. This rise of lawyers, this rise of compliance personnel that you didn’t have. Have we lost sight of what it is we do and what our values are and ensuring that we don’t deviate from that? Again, you kind of see that play itself out. We’re seeing it play itself out in real time in the Harvard conversations with the government. You hear talk about these are red lines. Well, why? So I thought that was, that’s getting me thinking. I put kind of a tongue in cheek. I was asked to do a speech for a big compliance conference and I put it a tongue in cheek sort of thing together saying we need to fundamentally rethink risk management, go from enterprise risk management to knowing what our mission is and taking every step to make sure that we are aligned with that mission. I like the way you framed it about Title IX. It’s like, if your focus is on we wanna make sure our students don’t get sexually assaulted. That’s our value, right? Title IX compliance kind of falls into place from there. Yeah, there’s some check-the-box stuff, but it’s secondary. If your mission is, we don’t want our students getting hurt, the other stuff falls in place. So having some sense of like, what are our values? And then assessing, are we living up to that? So I haven’t fully thought that through, but I’ll give a presentation in a couple of months and I’ll invite you all, after I’ve fully thought it through.

Paul Liebman

All right.

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Scott D. Schneider

Well, I’ll close on something that maybe puts it all together. Today is the 20th anniversary of Katrina, which Paulie knows my wife. I don’t know if you know this, but Wendy was like a week away from delivering our baby, who’s now 20 years old and studying in Korea at the time. And, I think of at Tulane, they certainly had prepared on the risk management side for hurricanes, but nothing like this and nothing prepared them or could prepare them for something like this. And I think of several things that came out of that catastrophe. One of which is, yeah, some institutions have been damaged beyond repair. Went to the University of New Orleans. That’s a school that in its heyday, I think, had roughly 20,000 students. It’s now struggling to survive at 4,000 or 5,000. And I think of a place like Tulane, which, I think the difference was, you had a leader in Scott Cowan, who viewed the crisis as a bit of an opportunity to course correct on some things, took those chances, and frankly developed an institution now that is on a trajectory that’s exponentially better than the one it was on before the storm. And again, we had Walter Kimbrough, who I love on the pod, he was talking about the second Trump administration is the Katrina of Trump administrations. And I do hope there is like, yeah, this is hard and how do we rethink things in light of this? The flip is I saw, I think it was Paul Fain on LinkedIn, posted something, I love Paul, Paul’s great, about Rachel Maddow is now the head of the Department of Education under the AOC administration. And now, using what happened in the Trump administration, she’s fining schools, hundreds of millions of dollars. But they’re the University of Tennessee’s and all these. If that’s the direction we’re going to be going, where this becomes normalized, rethinking our relationship with the government, what are our values, what are we not, what are the red lines? I think it’s going to be super important. I also think like Tulane, there’s the possibility of coming out of this moment with much better, more vibrant institutions or not. And there’s some that aren’t. So there, that’s my two cents. And by the way, anybody that says there’s anything positive about Katrina, they’re lying. It was hard.

Paul Liebman 

Well, I want to, if we’re going to close, I want to bring us back to the very beginning conversation. It’s not only the 20th anniversary of Katrina. It is the 61st anniversary, 61 years and one day of the most important day in music, which you may or may not be aware of, Scott. It is the day that Bob Dylan met the Beatles in New York. And Paul McCartney and John Lennon got high for the first time. And we can all agree, music changed forever. So they literally tape recorded and wrote notes of their experience, which are fascinating to read if you get an opportunity. But if you think about, in fact, the albums are separated. The greatest hits one is through 64, right? And the greatest hits two of the Beatles is 65 through 68-ish. I think we can both agree there’s a stark difference between the music that occurred in the second half of the 60s. And so every year, I have it on my calendar, every year on August 28th, I celebrate that day. I listen to the Beatles all day because it wasn’t only their music that changed, but it beget everything else. You know, the Stones.

Scott D. Schneider 

It’s a great segue into trying to find out what Eric Kelderman’s doing this weekend. All of sudden, Eric’s writing for the Chronicle is going to take on a Hunter Thompson-esque tone after this weekend.

Paul Liebman 

That’s right. 

Eric Kelderman 

I can neither confirm nor deny that there may be those kinds of influences involved in my life. This weekend.

Scott D. Schneider 

What are your plans this weekend, buddy?

Eric Kelderman 

So I don’t know if you know this, but I play on an adult baseball team. It’s a 48-and-over league. It’s a ridiculous amount of fun. And our first game was last weekend. We won. We have our next game is on Sunday at 3 p.m. If anybody wants to come, it’s at Kelly Park in Gaithersburg, Maryland. And so for me, it’s like it’s baseball season and I love playing. Still love playing. It’s a lot of fun. It’s hard to walk the next day because I catch several innings a game and that’s at my age, that’s a challenge. But it’s worth it.

Paul Liebman

I have a magnet that sits on my fridge that says, my favorite childhood memory is when my back didn’t hurt.

Paul Liebman 

And so, if you think it’s bad at your age, wait about another 14, 15 years, where you wake up…

Eric Kelderman 

Yeah. Well, I’m just, I’m only three years younger than you.

Paul Liebman 

Okay, well there you go. You look a lot younger than me. So there you go. 

Eric Kelderman 

It’s the camera.

Scott D. Schneider 

Because he doesn’t work with lawyers every day.  

Eric Kelderman

Yeah, that could be something. 

Scott D. Schneider

What you got going on this weekend, Paulie? You doing something fun?

Paul Liebman

Uh, my passions are live music and college sports. I can’t imagine a better place to be. And, so tonight, Vanderbilt women’s volleyball makes a reappearance after 30, 40 years where we’re kicking off women’s volleyball again. So we have a free game, on the Wyatt lawn, one of the big common quad areas. And then there’s a concert, when the game is over, there’s a concert for folks, who expect to have a few thousand people there. And then tomorrow night is opening of college football where the Commodores will kick off their season. And we love Diego Pavia, our quarterback who has been sticking it to the NCAA and we’ll get another year, I think he’s 25 now, maybe we’ll get one more year. But as long as he keeps beating Alabama, he can stay forever. I’ll turn a blind eye to it.

Scott D. Schneider

There you go. Cool.

Eric Kelderman

Scott?

Scott D. Schneider

Tonight we’re going out to see the Blues Specialist at the Continental Club and then tomorrow we’re getting into my truck and we’re going to go to start off in Lubbock, Texas to go watch Texas Tech football.

Paul Liebman 

Can I ask you a question about the Blues Specialist? Do they still have the keyboard player with the long fingernails?

Scott D. Schneider

I’ve never seen his fingernails. I don’t know.

Paul Liebman

I will tell you, I can’t remember his name. His daytime job was driving a city bus. I will just tell you that. And he used to, between driving the bus and appearing, by the way, the Continental Club is just literally my favorite place in the world. He used to smoke cigars. So were three of us that would go to this place at the old abandoned North Cross Mall, the Scotch Tape Mall as we call it because they had no stores and they had a cigar bar in there and me and one of my friends and he was always in there and we would smoke and then we would watch him. You would recognize him. He has like really really long fingernails. So we’ll be in there tonight. Take a look.

Scott D. Schneider 

I’m going to take a look and I’ll get a picture with him. But then, so we’re going to Lubbock tomorrow to watch Texas Tech football, which is this ascendant program that spent, I think, 30 million dollars on their football payroll. We can’t call it payroll. They’re on a NIL budget. And then we’re going to Taos, New Mexico. 

Paul Liebman 

Really?

Scott D. Schneider 

Yeah, I’m going to go work up there for a time being. So that’s the plan. Good stuff.

Paul Liebman 

Can I give you a music recommendation for your ride? 

Scott D. Schneider 

Sure.

Paul Liebman 

So the new album by St. Paul and the Broken Bones, have you heard them?

Scott D. Schneider 

Yes, I’ve seen them many times. That guy, the lead singer does my taxes.

Paul Liebman 

Okay, so they have a brand new album and the song Sushi and Coca-Cola is out right now and it’s a great album. It’s a very different sound than they used to have and I highly recommend it.

Eric Kelderman 

That’d be great.

Paul Liebman

Well, I’m excited. September 5th, I’m flying out to Denver and I’m going to see Pat Green, who I haven’t seen in many years. He’s back. He’s doing a little summer tour and that’s his last spot. And so, I’m looking forward to seeing Pat Green at some dive, like 100 person dive in Denver. 

Scott D. Schneider 

Cool, man.

Paul Liebman

So, yeah, it’s all good. Eric and Scott, thank you for having me. I enjoyed it. Now I’m going to go back into seclusion like I do. Nobody will know about me again.

Eric Kelderman 

Be well, thanks a lot, Paul.

Scott D. Schneider 

All right, buddy.

Paul Liebman 

All right. Bye. Yep.

Eric Kelderman 

Take care.

Paul Liebman

There you go. Well, look, thanks for tuning into Campus Docket. You’ll find links to everything we discussed today, including related cases, articles, and a full transcript, and the show notes, and on voltedu.com. Be sure to follow Campus Docket wherever you get your podcast. And while you’re there, check out Trusted Voices and Higher Voltage, two more podcasts in the Volt lineup that look at higher ed through different lenses. On behalf of the Volt team and my friend, Eric Kelderman. Thanks again for listening, we’ll see you next time.