Schaer v. Brandeis Univ.

432 Mass. 474, 735 N.E.2d 373 (2000)

 

RULE:

Courts are wary about interfering with academic and disciplinary decisions made by private colleges and universities. A university is not required to adhere to the standards of due process guaranteed to criminal defendants or to abide by rules of evidence adopted by courts. A college must have broad discretion in determining appropriate sanctions for violations of its policies.

FACTS:

A female student (complainant) filed a report with the university’s student judicial system. In the report, she stated that plaintiff David Arlen Schaer came to her dormitory room one morning after she had spoken with him on the telephone. The complainant alleged that, after they kissed, she told Schaer that she "did not want to have sex." She further alleged that she later awoke from sleep to find Schaer having intercourse with her. Thus, Schaer was suspended for approximately four months. Schaer filed a seven-count complaint in superior court against the university, seeking injunctive relief and compensatory damages. One superior court judge denied injunctive relief and another allowed a motion dismiss the entire complaint for failing to state a claim for which relief could be granted. Schaer appealed from the dismissal of his complaint and the appellate court affirmed for the most part, but reversed on the breach of contract claim.

ISSUE:

Did Schaer fail to state a claim on which relief may be granted?

ANSWER:

Yes.

CONCLUSION:

The court affirmed the judgment of dismissal of the superior court, concluding that Schaerhad failed to state a claim on which relief could be granted. Courts are chary about interfering with academic and disciplinary decisions made by private colleges and universities. A university is not required to adhere to the standards of due process guaranteed to criminal defendants or to abide by rules of evidence adopted by courts. A college must have broad discretion in determining appropriate sanctions for violations of its policies. The university was entitled to follow its own rules and Schaer’s allegations, even if true, did not establish breaches of contract by the university.

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