Academic freedom, at institutions of higher education, is discussed in terms of questions raised about the ability of an institution to dismiss an instructor. In the first case, "Martin v. Parrish," the instructor was dismissed for using profanity in the class. The second case, "Carley v. Arizona Board of Regents," centered on the importance of student evaluations in the ultimate dismissal of an instructor. The questions discussed are based upon the premise that teaching is an ambiguous technology. As such, with no specifying outcomes, can the means really be specified? If a university wishes to strengthen teaching, who will evaluate and on what criteria? Recommendations are offered at the institutional, collegial, and individual levels and include the following: require multiple measures of quality teaching; have a developmental process and goals; use a system appropriate to the institutional type; and (for the individual) raise academic freedom only as an institutional claim, not a legal one, since academic freedom is, in reality, an institutional, occupational and organizational norm, not a legally efficacious construct. (LMS)