Tedeschi v. Wagner College, 49 N.Y.2d 652 (1980)
A private educational institution is contractually bound by its own published rules and guidelines regarding student suspensions and must substantially observe those procedures.
Summary
Nancy Jean Tedeschi, a part-time student at Wagner College, was suspended after a series of disruptive incidents, including bizarre classroom behavior and harassing phone calls to a professor. The college notified Tedeschi of her suspension but did not provide a hearing as outlined in the college’s student guidelines. Tedeschi sued, arguing that the college violated her rights by not following its own procedures. The New York Court of Appeals held that while private colleges aren’t bound by the same due process requirements as public institutions, they are bound by their own published rules. The Court reversed the lower court’s decision and ordered the college to provide Tedeschi with the hearing prescribed in its guidelines.
Facts
Nancy Jean Tedeschi was a part-time student at Wagner College. She exhibited disruptive behavior in class, including repeatedly leaving and re-entering the classroom. Tedeschi tore up her Latin exam and subjected her Latin professor, Dr. Thompson, to harassing phone calls threatening suicide and harm to him. After Dr. Thompson contacted the police, the calls ceased. College officials contacted Tedeschi and her mother to discuss her academic situation, but Tedeschi refused to meet. Subsequently, she was orally advised of her suspension due to her bad character and disruptive behavior. A formal letter followed, confirming her withdrawal from classes for the spring semester. Her mother’s requests for a hearing were unsuccessful.
Procedural History
Tedeschi sued Wagner College, seeking reinstatement and damages, alleging she was not granted a hearing or opportunity to defend herself. The trial court ruled in favor of the college, finding no constitutional violation and deeming the suspension not arbitrary. The Appellate Division affirmed, with a dissent arguing the college was contractually bound to follow its own rules. Tedeschi appealed to the New York Court of Appeals.
Issue(s)
Whether a private college is legally bound to follow its own published rules and guidelines regarding student suspensions, even if those rules exceed the constitutional due process requirements applicable to public institutions.
Holding
Yes, because when a university has adopted a rule or guideline establishing the procedure to be followed in relation to suspension or expulsion, that procedure must be substantially observed.
Court’s Reasoning
The Court of Appeals reasoned that regardless of whether the relationship between a student and a private college is viewed as contractual or analogous to membership in an association, the college is bound by its own rules. The court emphasized that while academic decisions are generally reviewed deferentially for good faith, disciplinary suspensions warrant closer scrutiny. The Court stated, “[W]hen a university has adopted a rule or guideline establishing the procedure to be followed in relation to suspension or expulsion that procedure must be substantially observed.” In Tedeschi’s case, the college’s guidelines required a hearing before the Student-Faculty Hearing Board for non-academic suspensions, which Tedeschi did not receive. The court rejected the college’s argument that informal meetings sufficed or that Tedeschi waived her right to a hearing, holding that the college had an obligation to inform her of the procedures. The Court dismissed the claims for monetary damages and a due process hearing based on “state action” but directed the college to provide Tedeschi with the hearing required by its guidelines. The court highlighted that the review by the Student-Faculty Hearing Board offers a different perspective than that of the deans. Ignoring these rules, the court stated, “is to reduce the guidelines to a meaningless mouthing of words.”