Board of Curators of the University of Missouri v. Horowitz case brief

Board of Curators of the University of Missouri v. Horowitz case brief summary
435 U.S. 78 (1978)

CASE SYNOPSIS

Petitioner school board sought a writ of certiorari from a decision of the United States Court of Appeals for the Eighth Circuit which reversed the trial court's dismissal of respondent medical student's complaint that she was not afforded procedural due process prior to her dismissal for failure to meet academic standards.

CASE FACTS
The 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.

DISCUSSION

• 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. Constitution amendment 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.

OUTCOME

The appellate court's decision was reversed in favor of petitioner school board.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)