Univ. of Michigan v. Ewing
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474 U.S. 214 (1985)
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U.S. Supreme Court
Univ. of Michigan v. Ewing, 474 U.S. 214 (1985)
Regents of the University of Michigan v. Ewing
Argued October 8, 1985
Decided December 12, 1985
474 U.S. 214
Respondent was enrolled in a year program of study at the University of Michigan known as "Inteflex." An undergraduate degree and a medical degree are awarded upon successful completion of the program. To qualify for the final two years of the program, a student must pass an examination known as "NBME Part I." Respondent was dismissed from the University when he failed this examination with the lowest score recorded in the history of the Inteflex program. After unsuccessfully seeking, from University authorities, readmission to the program and an opportunity to retake the examination, respondent brought suit in Federal District Court, alleging a right to retake the examination on the ground, inter alia, that he had a property interest in the Inteflex program and that his dismissal was arbitrary and capricious in violation of his "substantive due process rights" guaranteed by the Fourteenth Amendment. While determining that respondent had a constitutionally protected property interest in continued enrollment in the Inteflex program, the District Court found no violation of his due process rights. The Court of Appeals reversed.
Held: Even if respondent's assumed property interest gave rise to a substantive right under the Due Process Clause to continue enrollment free from arbitrary state action, the facts of record disclose no such action. The record unmistakably demonstrates that the decision to dismiss respondent was made conscientiously and with careful deliberation, based on an evaluation of his entire academic career at the University, including his singularly low score on the NBME Part I examination. The narrow avenue for judicial review of the substance of academic decisions precludes any conclusion that such decision was such a substantial departure from accepted academic norms as to demonstrate that the faculty did not exercise professional judgment. Pp. 474 U. S. 222-228.
742 F.2d 913, reversed and remanded.
STEVENS, J., delivered the opinion for a unanimous Court. POWELL, J., filed a concurring opinion, post, p. 474 U. S. 228.