Michigan Case Law Update: Harris v. Mott Community College
MICHIGAN CASE LAW UPDATE
Harris v. Mott Community College
497 Mich 903 (November 25, 2014)
On November 25, 2014, the Michigan Supreme Court upheld the dismissal of a case filed by a former nursing student against Mott Community College and Nursing Program Administrators. The former student sued the College after he was dismissed from the Nursing Program due to safety violations in the clinical component of the program. The College dismissed the Plaintiff from the program despite having a 3.8 grade point average. The Plaintiff alleged that he was denied his right to procedural and substantive due process because he was not given notice or the opportunity to participate in the procedures outlined in the student handbook. The Plaintiff further alleged that the College breached the contract outlined in the handbook. The College argued that its student catalog disclaimed any contractual relationship and that any breach of fair dealing and honesty claims were unsupported by the evidence. Additionally, the College argued that the Plaintiff had notice and an opportunity to be heard regarding his safety violations. Lastly, the individual Defendants argued that they were entitled to governmental immunity. The trial court denied the College’s Motion for Summary Disposition and the College appealed. The Court of Appeals reversed the finding of the trial court. While the constitutional claims against the College were not barred by governmental immunity, the Court did find that the Plaintiff had not stated a claim for monetary relief against the individual employees. Regarding the constitutional issues, the Court of Appeals found that there was no genuine issue of material fact that the College and the individual Defendants were entitled to judgment as a matter of law. The Court found that the Plaintiff could not claim a property right based on the student handbook and that the handbook did not create a contractual right to continued enrollment at the College. Assuming without deciding that the Plaintiff had a property interest in his education protected by due process, the Court found that College officials adequately apprised the Plaintiff of his safety violations and that he was afforded sufficient procedures to comply with due process safeguards. Lastly, the Court agreed that courts in general should show great deference to genuinely academic decisions of institutions, upholding the Plaintiff’s dismissal from the College.
Patrick R. Sturdy is a partner in our Livonia office where he concentrates his practice on intellectual property, business law, education law, and employment and labor law. He may be reached at (734) 261-2400 or firstname.lastname@example.org.