Burt v. Bd. of Trs. of the Univ. of R.I. - 523 F. Supp. 3d 214 (D.R.I. 2021)

Rule:

To survive a Rule 12(b)(6) motion to dismiss, plaintiffs must plead a plausible entitlement to relief. Each complaint must have sufficient factual allegations that plausibly state a claim upon which relief can be granted. This standard requires more than a recitation of elements and must allow the Court to draw a reasonable inference that a defendant is liable.

Facts:

This order was a consolidation of motions to dismiss in five lawsuits brought by plaintiff individuals Sean Burt et al., and on behalf of all others against four universities in Rhode Island, defendants University of Rhode Island (URI), Brown University (Brown), Johnson & Wales University (JWU), and Roger Williams University (RWU). All the suits allege that defendant universities' decisions to transition from in-person to remote academic experiences in response to the COVID 19 pandemic amounted to breaches of contract and unjust enrichment. Suits against defendants Brown and JWU also charge the schools with unlawful conversion, and the latter also brings a claim of money had and received against JWU. All four universities have moved, pursuant to Fed. R. Civ. P. 12(b)(6), to dismiss the claims brought against them arguing that the complaints failed to sufficiently allege contractual promises for in-person education.

Issue:

Should the defendants’ motion to dismiss tuition class claims be granted?

Answer:

Yes.

Conclusion:

The court held that plaintiffs failed to sufficiently alleged plausible breach of contract claims against the universities regarding tuition payments, thus, the court granted defendants' motions to dismiss the counts. While this court's central finding was that nothing in the complaint indicated a contractual obligation for defendant universities to hold in-person programs, the unique nature of this moment warrants emphasis. The court held that defendants were responding to the remarkable circumstances of this pandemic which has upended countless aspects of our society's usual and customary practices. Therefore, one can reasonably infer that the universities reserved their rights for situations just like what occurred in 2020, which were unexpected events, in this case a global pandemic.