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Right to change academic standards for enrolled students - University of Mississippi Medical Center v. Hughes, 765 So.2d 528 (Miss. 2000)

This is an important case reviewing the standards that govern the right of a state university medical school to change its academic standards for students that have already enrolled.  Christopher W. Hughes and Eric Beasley, former medical students at the University of Mississippi Medical Center ("the University"), failed to pass Step One of the United States Medical Licensing Examination ("USMLE"). University guidelines state that if a student does not pass this examination in three attempts, the student will be dismissed from medical school. Pursuant to these guidelines, Hughes and Beasley were dismissed from the University. Hughes brought the present action for an injunction in the Hinds County Chancery Court, and Beasley intervened as a plaintiff. Plaintiffs claim that the University violated its contract with them by adding the requirement that students pass the USMLE to continue in school, arguing that once they have enrolled the University may not unilaterally change its graduation requirements.  They also claimed that as a public institution the University violated their due process and equal protection rights under the Constitution.  Chancellor Denise Owens ordered the University to readmit Hughes and Beasley so that they might afforded one more opportunity to take the examination. The University appeals this determination.

The court determined that there were no facts in dispute.  Since the appeal only concerns questions of law, the court conducted a de novo review of the Chancellor's decision.  The court began by stating that the role of the courts in reviewing academic decisions should be very limited - Regents v. Ewing, 474 U.S. 214, 226,  (1985) (declaring courts unsuited "to evaluate the substance of the multitude of academic decisions that are made daily by faculty members of public educational institutions").  The court found that the Chancellor's decision on the constitutional issues was ambiguous and cited to improper authority.  Since the constitutional issues were predicated on the validity of the contract arguments, the court considered those first and found that the University retained the right to change its standards:

"It is the conclusion of this Court, in keeping with the law of sister jurisdictions, that while the student-university relationship is contractual in nature, implicit in the university's general "contract" with its students is a right to change the university's academic degree requirements if such changes are not arbitrary or capricious. This conclusion is reached particularly in light of the great reluctance, expressed by numerous courts, including the United States Supreme Court, to intervene in the academic context.  A strict view of contract law--that it is a breach of contract for the University to modify its degree requirements in any instance after a student has enrolled--is rejected. Such a rule would interfere unnecessarily in the University's discretion to manage its academic affairs. Moreover, a strict view of the parties' relationship would require the conclusion that a new contract was formed each semester when Hughes paid his tuition. The protection afforded students comes from an implied contract right to continued free enrollment free from arbitrary interference--the protection afforded by the due process clause."

After a detailed analysis of the precedent cases on whether a student has a property right in continued enrollment, the court considered the plaintiffs' substantive due process claims that the University acted in a arbitrary and capricious manner in changing its academic standards without making adequate provision for students who were already enrolled.  The court first noted that the majority of medical schools required students to pass the USMLE before being promoted to their third year, and that these schools also limited the number of times students could take the exam.  The court next disposed of the plaintiffs' claim that they did not receive adequate notice, finding that the school had informed them of both the requirement of passing the test and that they would have a limited number of attempts to pass it.  Given these two factors - USMLE as a widely used standard, and adequate notice of the changed standard - the court found that the University had not acted in an arbitrary and capricious manner and dismissed plaintiffs' claims.

This is an important case with a detailed analysis of the precedent on judicial review of academic decisionmaking.

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