Board of Curators, Univ. of Missouri v. Horowitz - 435 U.S. 78 (1978)
U.S. Supreme Court
Board of Curators, Univ. of Missouri v. Horowitz, 435 U.S. 78 (1978)
Board of Curators of the University of Missouri v. Horowitz
Argued November 7, 1977
Decided March 1, 1978
435 U.S. 78
The academic performance of students at the University of Missouri-Kansas City Medical School is periodically assessed by the Council of Evaluation, a faculty-student body that can recommend various actions, including probation and dismissal; its recommendations are reviewed by the faculty Coordinating Committee, with ultimate approval by the Dean. After several faculty members had expressed dissatisfaction with the clinical performance of respondent medical student during a pediatrics rotation, the Council recommended that she be advanced to her final year on a probationary basis. Following further faculty dissatisfaction with respondent's clinical performance that year, the Council, in the middle of the year, again evaluated her academic progress, and concluded that she should not be considered for graduation in June of that year, and that, absent "radical improvement," she be dropped as a student. As an "appeal" of that decision, respondent was allowed to take examinations under the supervision of seven practicing physicians, only two of whom thereafter recommended that respondent be allowed to graduate on schedule. Two others recommended that she be dropped from the school immediately; and three recommended that she not be allowed to graduate as scheduled, but that she be continued on probation. The Council then reaffirmed its prior position. At a subsequent meeting, having noted that respondent's recent surgery rotation had been rated "low-satisfactory," the Council concluded that, barring reports of radical improvement, respondent should not be allowed to reenroll; and when a report on another rotation turned out to be negative, the Council recommended that respondent be dropped. When notified of that decision, which the Coordinating Committee and Dean had approved, respondent appealed to the Provost, who, after review, sustained the decision. Respondent thereafter brought this action against petitioner officials under 42 U.S.C. § 1983, contending, inter alia, that she had not been accorded due process prior to her dismissal. The District Court, after a full trial, concluded that respondent had been afforded all rights guaranteed by the Fourteenth Amendment. The Court of Appeals reversed.
1. The procedures leading to respondent's dismissal for academic deficiencies, under which respondent was fully informed of faculty dissatisfaction with her clinical progress and the consequent threat to respondent's graduation and continued enrollment, did not violate the Due Process Clause of the Fourteenth Amendment. Dismissals for academic (as opposed to disciplinary) cause do not necessitate a hearing before the school's decisionmaking body. Goss v. Lopez, 419 U. S. 565, distinguished. Pp. 435 U. S. 84-91.
2. Though respondent contends that the case should be remanded to the Court of Appeals for consideration of her claim of deprivation of substantive due process, this case, as the District Court correctly concluded, reveals no showing of arbitrariness or capriciousness that would warrant such a disposition, even if it were deemed appropriate for courts to review under an arbitrariness standard an academic decision of a public educational institution. Pp. 435 U. S. 91-92.
538 F.2d 1317, reversed.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and STEWART, POWELL, and STEVENS, JJ., joined, and in Parts I, II-A, and III of which WHITE, J., joined. POWELL, J., filed a concurring opinion, post, p. 435 U. S. 92. WHITE, J., filed an opinion concurring in part and concurring in the judgment, post, p. 435 U. S. 96. MARSHALL, J., filed an opinion concurring in part and dissenting in part, post, p. 435 U. S. 97. BLACKMUN, J., filed an opinion concurring in part and dissenting in part, in which BRENNAN, J., joined, post, p. 435 U. S. 108.