New York Law Review

Tag: University

  • Maas v. Cornell University, 94 N.Y.2d 87 (1999): Limits on Breach of Contract Claims Against Universities

    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.

  • People v. Leonard, 62 N.Y.2d 404 (1984): Lawfulness of Exclusion Orders on Publicly Accessible University Campuses

    People v. Leonard, 62 N.Y.2d 404 (1984)

    When prosecuting a trespass charge against an individual banned from a state university campus that is generally open to the public, the prosecution must prove that the banishment order was lawful, demonstrating a legitimate basis for the order that does not infringe upon the defendant’s statutory or constitutional rights.

    Summary

    Leonard, previously a student at SUNY-Binghamton, was issued a “persona non grata” letter by the university president, banning him from campus. He was arrested for criminal trespass after being found on campus and convicted. The New York Court of Appeals reversed, holding that the prosecution failed to prove the lawfulness of the banishment order. The Court emphasized that while universities have the power to maintain order, excluding someone from a publicly accessible campus requires demonstrating a legitimate basis for the exclusion that does not infringe upon the excluded individual’s rights. The prosecution cannot rely on a presumption of lawfulness; it must present evidence justifying the order.

    Facts

    Leonard had been a student at SUNY-Binghamton at various times over a 10 year period, but was not a student at the time of the incident. On February 23, 1981, the president of SUNY-Binghamton issued a “persona non grata” letter to Leonard, banning him from the campus and warning that he would be arrested if he returned. On October 23, 1981, Leonard was found at the Campus Pub, located in the University Union building on the SUNY-Binghamton campus, and was subsequently arrested.

    Procedural History

    Leonard was charged with criminal trespass in the third degree in Vestal Town Court. Prior to the non-jury trial, the parties stipulated that Leonard received the “persona non grata” letter, was not a student, faculty member, or employee at the time, was present on campus in October 1981, and that the campus and Campus Pub were “open to the public”. The trial court found the banishment order could be lawful even without any specific reason. The court declined to consider evidence on the order’s lawfulness. Leonard’s motion to dismiss was denied, and he was convicted. The County Court upheld the conviction. The New York Court of Appeals reversed.

    Issue(s)

    Whether, in a prosecution for criminal trespass on a university campus generally open to the public, the People must prove that an order banning the defendant from the campus was lawful.

    Holding

    Yes, because when prosecuting for criminal trespass on property “open to the public,” the People must prove that a lawful order excluding the defendant issued, and this includes demonstrating a legitimate basis for the order that does not infringe upon the defendant’s independent statutory or constitutional rights.

    Court’s Reasoning

    The Court of Appeals acknowledged the university’s general power under Education Law § 6450 to maintain order and exclude individuals who violate campus rules. However, the Court emphasized that this power is not absolute and cannot be exercised in a way that violates protected rights. The court reasoned that because the campus was stipulated to be “open to the public”, the prosecution had the burden to prove a lawful order was issued. To do so, the People must demonstrate that the exclusion order had a legitimate basis and did not unlawfully inhibit the defendant from engaging in constitutionally or statutorily protected conduct. The court stated that the power to exclude does not permit orders based on discriminatory factors or that impermissibly inhibit constitutionally protected activity. The Court rejected the argument that the prosecution could rely on a presumption that the university president acted lawfully, stating that such a presumption would unconstitutionally shift the burden of proof to the defendant. As the prosecution presented no evidence of a legitimate basis for the banishment order, the Court found that the People failed to meet their burden of proving every element of the crime beyond a reasonable doubt. The Court cited People v. Session, 34 N.Y.2d 254, 256, highlighting the impermissibility of presuming the lawfulness of official actions when it comes to proving elements of a crime.