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In the case of Morris v. Yale University, a medical student sued Yale University for breach of contract following his dismissal from school for his failure to successfully complete a required examination. To succeed in a breach of contract action, the medical student must prove: (1) the formation of an agreement; (2) the medical student performed as set forth in the agreement; and (3) Yale breached the agreement and caused the medical student damages as a result. However, the court is limited in its jurisdiction over educational institution, because the discretion of universities to make academic decisions concerning its student without judicial interference is widely recognized and predicated on sound policy. As a result, the court may only interfere unless the university is shown to have acted in bad faith or exercised their discretion arbitrarily.
The student was dismissed from the school in August 2004 after he failed to successfully complete an important examination which was required to allow him to progress in his education and graduate from the school. As a medical student, the student's academic and clinical abilities were found wanting in myriad ways which the court declines to recite here, except as necessary below. In addition to these difficulties, on August 17, 2002, the student failed in his first attempt to pass "Step I of the United States Medical Licensing Examination" ["Step I"], administered by the National Board of Medical Examiners, a requirement for graduation from the School of Medicine. The student alleges that, although the handbook expressly states that students have three opportunities to pass Step I, administered by the National Board of Medical Examiners, the university (1) did not actually allow the student to take Step I three times before dismissing him from the medical school, and (2) maintained the student's dismissal although he later passed the examination at another school on March 18, 2005.
The university established that there was no genuine issue of material fact that the language in its handbook, plainly read in a light most favorable to the student, did not give rise to the contractual obligation asserted by the student. The university had the discretion to dismiss the student, and the exercise of this discretion was not a breach of the terms of the [student] handbook. The provided evidence is clear that the university assisted, encouraged, and, ultimately demanded, that the student [pass the exam] or face dismissal, yet the student, himself, was unable or unwilling to do so” said the court. “Any claim that the student was induced by the university to repeatedly fail to meet the requisite standards and deadlines, in the face of the proffered evidence, are completely without merit.”
If you have a child with a disability and have questions about special education law, please contact Joseph C. Maya, Esq., at 203-221-3100, or at JMaya@mayalaw.com, to schedule a free consultation.
Source: Morris v. Yale Univ., 2012 Conn. Super. LEXIS 1216, 2012 WL 1959299 (Conn. Super. Ct. May 7, 2012)
