Noted: The case of Carolyn A. (Biddy) Martin at the University of Wisconsin at Madison demonstrates the limits imposed on the discretionary actions of senior university leaders. Last year, then-Chancellor Martin, with the apparent prompting of the governor, proposed to expand the university?s autonomy by breaking away from some restrictions imposed by the UW system. The key proposal would permit UW-Madison greater tuition autonomy, given its special status as a flagship research university.