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19th century In the 19th century, university professors largely served at the pleasure of the board of trustees of the university. Sometimes, major donors could successfully remove professors or prohibit the hiring of certain individuals; nonetheless, a de facto tenure system existed. Usually professors were only fired for interfering with the religious principles of a college, and most boards were reluctant to discipline professors. The courts rarely intervened in dismissals. In one debate of the Cornell Board of Trustees, in the 1870s, a businessman trustee argued against the prevailing system of de facto tenure, but lost the argument. Despite the power retained in the board, academic freedom prevailed. Another example is the 1894 case of Richard Ely, a University of WisconsinMadison professor who advocated labor strikes and labor law reform. Though the Wisconsin legislature and business interests pressed for his dismissal, the board of trustees of the university passed a resolution committing itself to academic freedom, and to retaining him (without tenur[citation needed]): "In all lines of academic investigation it is of the utmost importance that the investigator should be absolutely free to follow the indications of truth wherever they may lead. Whatever may be the limitations which trammel inquiry elsewhere we believe the great state University of Wisconsin should ever encourage that continual and fearless sifting and winnowing by which alone the truth can be found."[1] The notorious case of the dismissal of G. B. Halsted by the University of Texas in 1903 after nineteen years of service may have accelerated the adoption of the tenure concept. From 1900 to 1940 In 1900, the presidents of Harvard University, Columbia University, and the University of Chicago each made clear that no donor could any longer dictate faculty decisions; such a donors contribution would be unwelcome. In 1915, this was followed by the American Association of University Professors' (AAUP) declaration of principlesthe traditional justification for academic freedom and tenure. The AAUP's declaration of principles recommended that: Trustees raise faculty salaries, but not bind their consciences with restrictions. Only committees of other faculty can judge a member of the faculty. This would also insulate higher administration from external accountability decisions. Faculty appointments be made by other faculty and chairpersons, with three elements: (i) Clear employment contracts (ii) formal academic tenure, and (iii) clearly stated grounds for dismissal. While the AAUP pushed reform, tenure battles were a campus non-issue. In 1910, a survey of 22 universities showed that most professors held their positions with "presumptive permanence". At a third of colleges, assistant professor appointments were considered permanent, while at most colleges multi-year appointments were subject to renewal. Only at one university did a governing board ratify a presidents decisions on granting tenure. Finally, there were approximately 20 complaints filed in 1928 with the AAUP, and only one merited investigation. Colleges slowly adopted the AAUPs resolution; de facto tenure reigned; usually reappointments were permanent. Tenure is also offered in many states to public schoolteachers. Louisiana, under state education superintendent T. H. Harris, led the move to establish a teacher protection policy in the 1930s because of past political considerations in hiring and dismissal of educators.