McKee v. Southfield School
613 So.2d 659, 1993 WL 7936 (1993)
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Rule of Law:
A private school that implicitly promises a student academic credit by allowing them to continue attending and completing coursework, despite a parent's failure to pay tuition, may be obligated to release the student's transcript under the doctrine of detrimental reliance if the student reasonably relied on that promise to their detriment.
Facts:
- Charles Robert McKee IV was a student at Southfield School, a private institution, under annual enrollment contracts signed by his father.
- By the summer of 1990, McKee's tuition account was over $5,000 delinquent.
- Southfield's headmaster agreed to allow McKee to continue attending for the 1990-91 school year provided his father made monthly payments of $600 to clear the debt.
- McKee's father failed to adhere to the revised payment schedule, making only a few sporadic payments, and the delinquency grew to over $8,000.
- Despite the ongoing non-payment and breach of the payment agreement, Southfield permitted McKee to attend and complete the entire 1990-91 school year.
- At the end of that year, Southfield's upper school closed, forcing McKee to enroll at a new school, Trinity Heights Christian Academy, for his junior year.
- Southfield refused to release McKee's official academic transcript to Trinity until the outstanding debt was paid.
- Without the transcript, McKee was prohibited from playing on the school basketball team and faced the possibility of having to repeat two years of high school to graduate from Trinity.
Procedural Posture:
- Charles Robert McKee IV filed a Petition for Damages and Equitable Remedies against Southfield School in a Louisiana state trial court.
- McKee sought a temporary restraining order, as well as preliminary and permanent injunctions, to compel the release of his transcript.
- The trial court denied the temporary restraining order.
- Following a hearing, the trial court granted a preliminary mandatory injunction ordering Southfield School to deliver one official transcript to McKee.
- Southfield School, as defendant-appellant, filed a suspensive appeal to the Court of Appeal of Louisiana, Second Circuit. McKee is the plaintiff-appellee.
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Issue:
Does a private school's act of allowing a student to remain enrolled and complete a school year, despite the parent's failure to pay tuition, create an enforceable obligation for the school to release the student's academic transcript under the doctrine of detrimental reliance?
Opinions:
Majority - Judge Norris
Yes. Although McKee cannot enforce the original contract due to his father's breach, he can demand the transcript based on the doctrine of detrimental reliance. By permitting McKee to remain enrolled and complete his coursework for the entire year despite the unpaid tuition, Southfield implicitly promised McKee he would receive academic credit and the necessary documentation for that credit. McKee reasonably relied on this promise by continuing to attend school and perform his academic duties. To withhold the transcript now would be a detriment to McKee, as it would force him to repeat two years of school and prevent him from participating in athletics. Therefore, Southfield is estopped from withholding the transcript.
Dissenting - Judge Victory
No. Southfield's decision not to disenroll McKee cannot be construed as an implied promise to release his transcript without payment; at most, it was an implied promise not to expel him mid-semester. McKee did not rely on Southfield's actions to his detriment; on the contrary, he benefited by being allowed to complete the school year when he could have been expelled. He is in a better position than if Southfield had strictly enforced the contract. Furthermore, any reliance would have been unreasonable, as McKee was aware of his father's failure to pay. The majority's application of detrimental reliance forces a non-breaching party to fully perform and creates a poor policy incentive for schools to immediately expel students with delinquent accounts.
Analysis:
This case establishes that a party's course of conduct, such as allowing a student to continue their education, can create an enforceable promise under the doctrine of detrimental reliance, even when the underlying contract has been breached. The decision extends this protection to a student as a third-party beneficiary, shielding them from the harsh consequences of a parent's financial breach when the school has implicitly promised to grant academic credit through its actions. This creates a tension for private educational institutions, forcing them to weigh the financial risk of leniency against the potential legal obligation to provide records, possibly leading to stricter enforcement of tuition policies as the dissent warns.
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