Hall v. Capella University

Background

Aric W. Hall sued Capella University over his disenrollment from Capella’s Ph.D. program in February 2012. Hall had enrolled in the program in 2003. He alleged that a dissertation advisor did not respond to multiple draft dissertation templates, sign off on milestones, or communicate with him. He also alleged that unnamed university advisors said they would seek an extension and find him a new dissertation advisor, but Capella disenrolled him.

Hall had filed an earlier related case. The court dismissed many earlier allegations as barred by the statute of limitations or the educational-malpractice doctrine. It dismissed the fraud and breach-of-contract claims concerning the 2012 disenrollment without prejudice, allowing Hall to file another complaint with more specific facts. In January 2018, Hall filed this case against Capella, alleging fraud and false advertising.

Fraud claim

The court applied Minnesota law and Federal Rule of Civil Procedure 9(b), which requires fraud to be pleaded with particularity. In practical terms, a complaint must identify the who, what, where, when, and how of the alleged fraud.

The court held that Hall did not identify a specific false representation. He generally alleged that Capella promised him an opportunity to pursue a Ph.D., but he did not explain who made the promise or what specific services Capella promised to provide. He also referred generally to statements in Capella’s milestones and catalogs without identifying their contents or explaining why they were false. The court further held that Hall did not plead facts showing that Capella knew the statements were false or made them without knowing whether they were true or false.

The court also rejected the part of the fraud claim based on advisors’ statements that they would seek an extension or find a new dissertation advisor. Hall did not name those advisors, allege facts showing that they knew the statements were false or were indifferent to their truth, or allege that the advisors failed to follow through. The court therefore dismissed the fraud claim.

False-advertising claim

The court explained that Minnesota law prohibits intentionally publishing a false or misleading advertisement and allows an injured individual to bring a civil action for a violation. Because the claim is based on alleged fraud, the court applied the same particularity requirement.

The court held that Hall failed to identify a false or misleading published statement, state the statement’s content, explain why it was false or misleading, or provide its publication date. The court therefore dismissed the false-advertising claim.

Disposition

The court noted that this was Hall’s second opportunity to plead the claims with sufficient particularity. It granted Capella University’s motion to dismiss and ordered that the case be dismissed with prejudice. The order directed that judgment be entered accordingly.

Classification

This is a procedural order because the court dismissed the claims under the pleading requirements governing a motion to dismiss rather than deciding whether Capella was actually liable for fraud or false advertising.