Maas v. Cornell University, 94 N.Y.2d 87 (1999)
An employee cannot bring a breach of contract action against a university for failing to follow its internal procedures for resolving disputes, absent evidence of an express agreement or detrimental reliance.
Summary
Professor Maas sued Cornell University, alleging breach of contract for failing to adhere to its internal procedures when handling sexual harassment claims against him. The New York Court of Appeals held that Maas could not maintain a plenary breach of contract action. The Court reasoned that universities are best suited to handle internal matters and that the University’s adherence to its own procedures does not create a contractual relationship that is subject to judicial review in a plenary action. The proper avenue for judicial review is a CPLR Article 78 proceeding, which Maas initially opposed.
Facts
James Maas, a tenured psychology professor at Cornell University, was accused of sexual harassment by four students in 1994. The University processed the complaints under its internal procedures. Following an investigation and hearings, the Professional Ethics Committee found that Maas had engaged in unprofessional conduct and sexual harassment. The Dean of the College upheld the Committee’s determination, and an appeal to the Provost was rejected. Maas remained a tenured faculty member.
Procedural History
Maas filed suit against Cornell, alleging multiple causes of action, including breach of contract and negligence. The Supreme Court dismissed most of the claims, refusing to convert the action into a CPLR Article 78 proceeding. The Appellate Division affirmed. After remittal, the Supreme Court granted summary judgment to Cornell on the remaining negligence claims. The Appellate Division affirmed again, rejecting Maas’s request for CPLR Article 78 conversion because he had previously opposed it. The New York Court of Appeals granted Maas leave to appeal.
Issue(s)
1. Whether a university’s internal regulations and procedures create a contractual relationship with its employees, such that a violation of those procedures can form the basis for a breach of contract action.
2. Whether the lower courts erred in refusing to convert Maas’s plenary action into a CPLR Article 78 proceeding.
Holding
1. No, because administrative decisions of educational institutions involve specialized professional judgment, and these institutions are generally better suited to make final decisions concerning internal matters.
2. No, because Maas initially opposed the conversion to a CPLR Article 78 proceeding and cannot now seek such relief after his plenary action was dismissed.
Court’s Reasoning
The Court emphasized that universities are best suited to resolve internal disputes, and courts should exercise restraint in applying traditional legal rules to academic matters. The Court stated, “In these so-called ‘university’ cases, CPLR article 78 proceedings are the appropriate vehicle because they ensure that the over-all integrity of the educational institution is maintained and, therefore, protect more than just the individual’s right to employment.”
The Court found that Maas’s breach of contract claim failed because he did not demonstrate that Cornell intended its internal procedures to become part of his employment contract. The Court distinguished the case from wrongful termination disputes, where detrimental reliance on an employer’s written policies can create contractual obligations. The Court reasoned that “Cornell cannot be held to have contractually bound itself to follow these internal rules when it hired Maas.”
The Court also cited Restatement (Second) of Contracts § 4, noting that an implied-in-fact contract requires mutual agreement and an intent to promise, which were not present in this case. The Court noted that “the concept of handbooks as part of a contract with commitments and expectations on both sides’ is not universally accepted”.
The Court distinguished Tedeschi v. Wagner College, stating that while universities must substantially observe their procedures for suspension or expulsion, the legal theory underlying that rule is not well-defined and does not necessarily create a contract. The Court concluded that Maas failed to plead a cognizable breach of contract action and affirmed the lower courts’ decisions.