Board of Curators of University of Missouri v. Horowitz

435 U.S. 78



Due process requires, in connection with the suspension of a student from public school for disciplinary reasons, that the student be given oral or written notice of the charges against him and, if he denies them, an explanation of the evidence the authorities have and an opportunity to present his side of the story.


A medical student was dismissed by officials of the school during her final year of study for failure to meet academic standards. The medical student filed suit against the school board under 42 U.S.C.S. § 1983, alleging that she was not afforded procedural due process prior to her dismissal. The school board contended that the procedures that it employed when dismissing the medical student were sufficient to satisfy the requirements of procedural due process.


Was the student’s due process right violated when she was immediately dismissed by the school without any explanation by the student?




The appellate court's decision was reversed in favor of petitioner school board. The court reversed the appellate court's decision. Assuming the existence of a liberty or property interest, the medical student was awarded at least as much due process as U.S. Const. amend. XIV required. The determination whether to dismiss a student for academic reasons required an expert evaluation of cumulative information and was not readily adapted to the procedural tools of judicial or administrative decisionmaking. Under those circumstances, the court declined to formalize the academic dismissal process by requiring a hearing.

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