An exhibit in a display case near the history department of the University of Minnesota, Duluth, featured a photograph of two history professors clowning around. The photo showed Albert Burnham wearing a coonskin cap and holding a pistol, with his colleague Ronald Marchese holding a Roman short sword. Students complained that photographs of two white males in such quasi-military attire was "offensive" and that it "contributed to the climate of fear" on campus.

UMD President Lawrence Ianni agreed, ordering campus police to remove the photograph. But the two professors sued Ianni for $1.2 million on First Amendment grounds, and a federal appeals court recently ruled that the case could proceed and that the professors could collect from Ianni personally in the event of victory.

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