John Dewey's law contends that teacher-student intimacy makes significant contribution to meaningful classroom learning. Considering teacherly love as a criterion for tenure takes significant steps toward creation of a teacher retention system that makes tenure worth having, ties tenure to professional development, and creates an infrastructure for democratic schooling. Dewey's law contributes to discussions of teacher tenure by bringing democratic schooling to the forefront of considerations about guidelines for teacher retention. As with teacher accountability, research indicates widespread dissatisfaction among teachers, school district supervisors, and the American public alike with teacher tenure regulations that connect retention decisions in whole or in part to student achievement on standardized tests. Lisa S. Goldstein offers a tripartite theory of teacherly love that implicitly offers some criteria to guide tenure decisions. As Goldstein summarizes her argument, "Teaching with love brings intimacy into the classroom equation, moving education a tremendous step ahead of what is possible through passion and commitment alone".