Bhatnagar v. The New School

Background

Sankalp Bhatnagar was a student in the school’s two-year Transdisciplinary Design graduate program from fall 2016 through May 2018. The second year focused largely on a thesis. After four semesters, Bhatnagar had not completed his thesis and had three incomplete grades. He left New York for the summer without an approved extension.

The dean set deadlines for Bhatnagar to submit additional work, eventually extending the final deadline to August 25, 2018. Bhatnagar submitted two pages related to his proposed thesis in July and nothing further. On August 31, 2018, the school awarded him a Master of Fine Arts degree without a completed written thesis and gave him a C+ for his thesis work. Bhatnagar alleged that the school breached an implied contract and discriminated against him based on a perceived mental disability by awarding the degree, giving him a C+, and refusing to let him continue for a third academic year.

Motions and legal standards

Bhatnagar moved for partial summary judgment on his breach-of-contract claim. The school cross-moved for summary judgment on all claims. Summary judgment is appropriate when the evidence shows no genuine dispute about a fact that could affect the result and the moving party is entitled to judgment as a matter of law.

Americans with Disabilities Act claim

Bhatnagar’s claim arose under Title III of the Americans with Disabilities Act, which allows a private individual to seek an injunction but not damages. The only injunction Bhatnagar requested concerned preventing future discrimination against other students. The court held that this alleged future harm was too speculative to establish an actual injury and that the requested injunction would not remedy an injury to Bhatnagar himself.

The court therefore dismissed the Americans with Disabilities Act claim without prejudice for lack of subject-matter jurisdiction. The court’s conclusion states that the school’s motion was denied without prejudice as to this claim, while also stating that the claim was dismissed without prejudice.

Rehabilitation Act claim

Section 504 of the Rehabilitation Act prohibits a program receiving federal funds from excluding or discriminating against a person because of a disability. The court applied the burden-shifting framework used for discrimination claims. Even assuming Bhatnagar made the initial showing required to proceed, the court held that the school presented nondiscriminatory reasons for its actions.

The court relied on undisputed evidence that Bhatnagar had not completed his coursework or thesis and had an adversarial relationship with the program and faculty. It concluded that no reasonable jury could find that Bhatnagar’s mental health was the sole reason for the school’s decisions or that the school’s stated reasons were a pretext for discrimination. The court also noted that Bhatnagar did not support his argument that awarding a degree and a grade could constitute a denial of benefits under the Rehabilitation Act.

The school’s motion for summary judgment on the Rehabilitation Act claim was granted.

Breach-of-contract claim

Under New York law, a breach-of-contract claim requires an agreement, adequate performance by the plaintiff, a breach by the defendant, and damages. The parties did not dispute that an implied contract existed between the school and Bhatnagar.

The court held that the school was entitled to summary judgment because no reasonable jury could find that Bhatnagar adequately performed his obligations. He did not submit a thesis by the extended deadline and submitted only two additional pages related to his thesis. The court explained that a student’s obligations under the implied contract include satisfying the school’s academic requirements and following its procedures.

The school’s motion for summary judgment on the breach-of-contract claim was granted, and Bhatnagar’s motion for summary judgment on that claim was denied. The court rejected Bhatnagar’s argument that the school breached the contract by giving him a passing grade and degree despite his failure to meet the requirements, reasoning that the school’s performance despite Bhatnagar’s nonperformance did not support a breach-of-contract claim.

New York State and New York City claims

The court declined to exercise supplemental jurisdiction over Bhatnagar’s claims under the New York State Human Rights Law and the New York City Human Rights Law. Supplemental jurisdiction allows a federal court to hear related state-law claims, but the court may decline when the federal claims have been dismissed before trial or when the state-law issues are novel or complex.

The court found that the state claims raised unresolved or complex issues, including the causation standard under the state law and the scope of the New York City law’s education-related exclusion. The claims were dismissed without prejudice to refiling in state court.

Disposition

The school’s motion for summary judgment was granted as to the Rehabilitation Act and breach-of-contract claims. It was denied without prejudice as to the Americans with Disabilities Act, New York State Human Rights Law, and New York City Human Rights Law claims. Bhatnagar’s motion for partial summary judgment was denied. The school’s motion for oral argument was denied as moot, and the case was closed. Judge Lorna G. Schofield signed the opinion and order.