Jones v. Capella University

Background

LaTreka Jones alleged that she enrolled in Capella University’s bachelor’s program and eventually had one course remaining to complete her degree. Capella allowed her to attend a commencement ceremony before she completed the requirements, and she traveled from Texas to Minnesota with her family for the ceremony. During her final course, Jones experienced a divorce, cared for her disabled son, faced her brother’s death, and dealt with challenges from Hurricane Harvey. She alleged that an academic advisor instructed her professors to provide accommodations, including assignment extensions, but that she nevertheless received low or zero credit on some assignments.

On her final assignment, professor Julie Johnson used a source-matching tool and determined that Jones had plagiarized 55 percent of the assignment. Capella’s review process resulted in a finding of plagiarism and Jones’s dismissal from the university. Jones appealed unsuccessfully.

Jones’s original complaint alleged that Capella had violated unspecified rights. Capella moved to dismiss that complaint for failure to state a claim. Jones then moved to amend. Her proposed amended complaint removed the individually named defendants and asserted three claims against Capella: unjust enrichment, promissory estoppel, and violations of the Minnesota Deceptive Trade Practices Act.

Motion to Amend

The court applied Federal Rule of Civil Procedure 15(a)(2), which generally favors allowing amendments, but explained that an amendment may be denied when it would be futile. An amendment is futile if the proposed complaint could not survive a motion to dismiss for failure to state a claim under Rule 12(b)(6).

Unjust Enrichment

Under Minnesota law, unjust enrichment requires a benefit conferred on the defendant, the defendant’s knowing acceptance of that benefit, and circumstances making retention of the benefit inequitable. Jones argued that it was unjust for Capella to retain her tuition because she did not receive a degree.

The court rejected that theory. Relying on Minnesota law, it explained that the benefit exchanged for tuition was instruction, not a degree. The proposed complaint did not allege that Jones paid tuition in exchange for a promise that Capella would award her a degree regardless of whether she completed her coursework. The court therefore concluded that the proposed complaint failed to state an unjust-enrichment claim.

Promissory Estoppel

Promissory estoppel requires a clear and definite promise, an intent to induce reliance, reliance causing detriment, and enforcement necessary to prevent injustice. Jones alleged that Capella promised to issue her a bachelor’s degree in exchange for tuition payments.

The court found that Jones did not plausibly allege a clear and definite promise. The proposed complaint did not identify when Capella made the alleged promise, who made it, or the surrounding circumstances. The court also noted that Jones understood she had to pass her remaining coursework to earn a degree. It therefore concluded that the proposed complaint failed to state a promissory-estoppel claim.

Minnesota Deceptive Trade Practices Act

Jones alleged that Capella’s policy of assessing academic dishonesty case by case and imposing consequences on a sliding scale created a likelihood of confusion or misunderstanding under the Minnesota Deceptive Trade Practices Act.

The court held that the claim was futile for two reasons. First, it amounted to an educational-malpractice claim because deciding it would require the court to review Capella’s academic-dishonesty policies and the educational and administrative factors behind them. Minnesota does not allow such educational-malpractice claims, although it permits certain claims based on specific promises, fraud, or misrepresentation by educational institutions.

Second, the court held that Jones did not satisfy the heightened pleading requirement for claims involving fraud or mistake. Her allegations did not state with particularity the basis for her claimed inference about Capella’s policy, any action by Capella that caused her to draw that inference, or the intent required to mislead. The court therefore concluded that the proposed complaint failed to state a claim under the Minnesota Deceptive Trade Practices Act.

Motion to Dismiss the Original Complaint

The court liberally construed Jones’s original complaint because she originally litigated without a lawyer. Even under that standard, the court found that the complaint failed to state a claim.

The court characterized Jones’s allegations as educational-malpractice claims because they asked the court to review Capella’s grading decisions and determine whether Capella provided adequate academic accommodations. The court stated that it would not review the university’s academic decisions absent compelling evidence that the academic policy was a pretext for discrimination. The court also found that the original complaint did not plausibly allege a contract claim because it identified no specific and definite offer, and that it did not plausibly allege promissory estoppel because it identified no clear and definite promise.

Disposition

The court denied Jones’s motion to amend the complaint, granted Capella’s motion to dismiss, and dismissed the case with prejudice. The court directed that judgment be entered.