22 N.Y.3d 213 (2013)
A court will not overturn a law school’s decision to rescind admission unless the school acted arbitrarily, failed to follow its own rules, or imposed a penalty that shocks the conscience.
Summary
The New York Court of Appeals upheld St. John’s University School of Law’s decision to rescind David Powers’s admission after he had completed three semesters, due to material misrepresentations and omissions in his application concerning his criminal history. Powers failed to fully disclose the nature of his drug-related charges and convictions. The Court found that the law school’s actions were rational, consistent with its policies, and did not violate its own procedures. The court emphasized the university’s broad discretion in admissions decisions and the applicant’s notice of potential consequences for providing false information. The rescission was deemed appropriate given the misrepresented criminal background and the school’s interest in the integrity of its graduates.
Facts
David Powers applied to St. John’s University School of Law, disclosing a past drug-related conviction but failing to fully describe the charges and convictions accurately. His application misrepresented the details of his convictions, omitting the distribution and possession with intent to distribute LSD charges, which were more serious than he indicated. After completing three semesters, Powers sought a letter of support to the Committee on Character and Fitness for the New York bar. His disclosure to the Committee revealed additional details about drug distribution. St. John’s then investigated the inconsistencies between his application and his disclosures to the Committee. The school gave Powers an opportunity to amend his application, but he declined. The law school then rescinded his admission.
Procedural History
Powers initiated an Article 78 proceeding in the trial court to challenge the law school’s decision. The trial court ruled in favor of the law school. The Appellate Division affirmed the trial court’s decision, concluding that the law school’s determination was not arbitrary or capricious. Powers then appealed to the New York Court of Appeals, which affirmed the Appellate Division’s decision.
Issue(s)
1. Whether St. John’s University School of Law acted arbitrarily and capriciously in rescinding Powers’s admission to the law school.
2. Whether the law school failed to follow its own rules and procedures.
3. Whether the penalty of rescission was so excessive that it shocked one’s sense of fairness.
Holding
1. No, because the law school’s decision was rational and based on the applicant’s misrepresentations and omissions concerning his criminal history.
2. No, because the formal grievance procedures outlined in the student handbook did not apply to the application process.
3. No, because given the law school’s clear warnings about the consequences of providing false information on an application, the penalty of rescission was not excessive.
Court’s Reasoning
The Court of Appeals emphasized that courts have a