It's not clear whether Ward Churchill has received his $1 check yet, but he should soon be receiving a bill from the University of Colorado for the more than $10,000 in legal fees incurred during his wrongful termination suit. The announcement follows a ruling earlier this week by Denver District Judge Larry Naves, who vacated a jury's findings that the university's Board of Regents were wrong to fire Churchill from his position as an ethnic studies professor and award him $1. Churchill plans to appeal the case, according to The Denver Post [2], and that could mean a delay in payment for the public university, funded in part by taxpayers. Westword [3] points out that "Shouting Fire: Stories From the Edge of Free Speech [4]," a recent HBO documentary, implies that the case against Churchill was about his controversial political views rather than academic misconduct. But the blog for the American Council of Trustees and Alumni [5], an organization founded by Jerry L. Martin, the former chairman of the philosophy department at CU-Boulder, argues that the court decision means universities now need to "ensure their institutions have rigorous post-tenure review policies that combine 'carrots' and 'sticks,' conduct regular assessments of whether the process is working, make any necessary improvements, and publish both their policies and their assessments."