Doe v. Columbia University

Background

John Doe, a Chinese citizen and former student in Columbia University’s graduate program in the School of Professional Studies, alleged that Columbia improperly expelled him and denied him a master’s degree. He alleged that he had paid his tuition, completed his coursework, and maintained a 3.30 grade-point average. Columbia accused him of submitting false materials in his admission application, which it treated as “dishonesty” under its Student Conduct and Community Standards.

Columbia held a disciplinary hearing by web conference on September 13, 2018, and expelled Doe. According to Doe, Columbia later vacated that decision after his appeal and allowed him to continue his studies. Columbia then issued a November 19, 2018 letter affirming the expulsion. Doe alleged that Columbia did not provide adequate notice or a hearing before the later decision and that it expelled international students for financial reasons. Columbia denied the legal significance of those allegations and argued that Doe’s claims were untimely or inadequately pleaded.

Doe asserted six causes of action: breach of contract, breach of the implied covenant of good faith and fair dealing, arbitrary expulsion, unjust enrichment, equitable estoppel, and declaratory judgment. Columbia moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to state a legally plausible claim.

Article 78 Claims

The court held that Doe’s claims for arbitrary expulsion, equitable estoppel, and declaratory judgment sought to overturn Columbia’s academic and disciplinary decisions. Under New York Civil Practice Law and Rules Article 78, challenges to decisions by private universities generally must be brought within four months.

The court distinguished those claims from Doe’s contract-based claims, which it said were not appropriate for an Article 78 proceeding. But it concluded that the requested relief—reversing the expulsion findings, restoring Doe’s reputation, removing the expulsion from his records, reinstating him, and awarding him a master’s degree—would require review of Columbia’s academic decision. Because Columbia affirmed its decision on November 19, 2018, and Doe filed suit on June 7, 2019, the court held that these three claims were barred by Article 78’s four-month statute of limitations. The court dismissed the third, fifth, and sixth causes of action.

Breach of Contract

The court recognized that an implied contract may arise between a student and a university. That contract can include promises in university rules and regulations, including procedures for suspension or expulsion. To state a contract claim, however, a plaintiff must identify a specific contract, specific services or promises, and the university’s failure to provide those services or keep those promises.

The court rejected Columbia’s argument that Doe admitted his application contained false materials. The court found that Doe clearly disputed that allegation and alleged that his application documents were true or that any false materials may have been submitted by the agency through which he applied.

The court nevertheless dismissed the contract claim. It concluded that Columbia followed its disciplinary procedures. The September 4 notice identified the alleged misconduct as dishonesty, stated that false information had been submitted in Doe’s application, and referred to his transcript and the application prompt requiring confirmation that the admission materials were accurate. The Community Standards did not require an in-person hearing, and the notice informed Doe that the hearing would take place by web conference. The court also concluded that the November 19 letter was the result of Doe’s appeal, not a separate disciplinary decision requiring another notice or hearing, because the Community Standards did not provide a right to additional notice or a hearing after an appeal.

The court therefore concluded that Columbia did not improperly take Doe’s money, waste his time, or expel him, and that it properly refused to award him a degree. It dismissed the breach-of-contract claim.

Other Claims and Disposition

The court dismissed Doe’s claim for breach of the implied covenant of good faith and fair dealing because it repeated the same allegations as his contract claim. Under the court’s description of New York law, a separate implied-covenant claim cannot proceed when it arises from the same facts as a breach-of-contract claim.

The court also dismissed the unjust-enrichment claim. It concluded that the implied contract governed the parties’ relationship and gave Columbia the right to act as it did, so Doe could not pursue unjust enrichment based on the same subject matter.

In the conclusion, the court granted Columbia’s motion to dismiss as to all counts. The court also dismissed Doe’s motion to proceed anonymously as moot, directed the clerk to terminate the motions, and closed the case.