Halasz v. University of New England
816 F. Supp. 37, 1993 U.S. Dist. LEXIS 3143, 1993 WL 74393 (1993)
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Rule of Law:
Under Section 504 of the Rehabilitation Act, an educational institution is not required to lower or fundamentally alter its academic standards to accommodate a student with a disability. A student is not "otherwise qualified" if they cannot meet the program's academic requirements even with reasonable accommodations.
Facts:
- Halasz, a student with a learning disability and Tourette's Syndrome, applied for transfer admission to the University of New England (U.N.E.).
- His academic record was poor, including a cumulative GPA of 1.98 from three prior colleges, numerous high school failures, very low SAT scores, and a required withdrawal from a previous university for academic reasons.
- U.N.E. offered special programs for learning disabled students: the Individual Learning Program (ILP) for regularly admitted students and the First Year Option (FYO) for students who did not meet regular admission criteria.
- Based on his academic record, U.N.E. denied Halasz regular admission but admitted him to the FYO program, a transitional path requiring a 2.0 GPA over two semesters to gain admission to the regular baccalaureate program.
- Halasz enrolled in the FYO program and received accommodations such as tutors, untimed testing, and counseling.
- In his first semester, Halasz earned a 1.75 GPA; in his second semester, his cumulative GPA dropped to 1.375.
- Because his GPA of 1.375 was below the 2.0 required for matriculation from the FYO program, U.N.E. did not admit him to its regular degree program.
Procedural Posture:
- Plaintiff Halasz filed a lawsuit against the University of New England in the United States District Court for the District of Maine (the court of first instance).
- The complaint sought declaratory and injunctive relief, as well as damages, for alleged violations of Section 504 of the Rehabilitation Act.
- Defendant University of New England filed a motion for summary judgment, asking the court to rule in its favor without a full trial.
- Plaintiff Halasz filed an objection to the Defendant's motion for summary judgment.
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Issue:
Does an educational institution violate Section 504 of the Rehabilitation Act by denying a student with a learning disability admission to its regular degree program when the student's academic record fails to meet the institution's minimum standards, even after the institution offered a specialized preparatory program as an accommodation?
Opinions:
Majority - Carter, J.
No. An educational institution does not violate the Rehabilitation Act by denying admission to a student who fails to meet its academic standards, as the Act does not require institutions to lower those standards. Halasz was not an "otherwise qualified" individual because his academic history demonstrated he was not qualified for regular admission. U.N.E. provided a reasonable accommodation by offering admission to the FYO program, which gave Halasz an opportunity to prove his capabilities. The higher GPA requirement (2.0) for FYO students to matriculate was rationally justified because they took a lighter course load, and the standard was necessary to predict success in the more demanding regular program. Even with accommodations, Halasz failed to meet the FYO program's requirements, demonstrating he was not qualified for the regular baccalaureate program.
Analysis:
This decision reinforces the principle established in Southeastern Community College v. Davis that Section 504 of the Rehabilitation Act mandates non-discrimination and reasonable accommodation, not affirmative action or fundamental alterations of program standards. It clarifies that an applicant must first be 'otherwise qualified' to trigger the institution's full accommodation duties regarding admission. The case validates the use of conditional or preparatory programs as a form of reasonable accommodation and affirms that universities may apply different, rationally-justified academic standards to such programs to ensure students are prepared for the rigors of the standard curriculum.
