Reardon v. Allegheny College
2007 Pa. Super. LEXIS 1572, 2007 Pa. Super. 160, 926 A.2d 477 (2007)
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Rule of Law:
The relationship between a student and a private college is contractual, and courts will not review the merits of a college's disciplinary decisions so long as the institution substantially adheres to the procedures outlined in its student handbook.
Facts:
- Laura Reardon was a student at Allegheny College, a private institution.
- In the spring of 2004, Reardon was enrolled in a biology course taught by Professor Margaret Nelson.
- Professor Nelson assigned Reardon, Stacy Miller, and Megan Reilly to work as a group on a lab experiment, but each student was required to submit an individual paper.
- Upon reviewing the submissions, Professor Nelson discovered that Reardon's and Reilly's papers contained identical sections.
- Professor Nelson concluded that Reardon had plagiarized and reported the matter to the Allegheny College administration for disciplinary action.
- Allegheny College's student handbook, known as The Compass, outlined the specific procedures for adjudicating alleged violations of its Honor Code.
Procedural Posture:
- Laura Reardon sued Allegheny College, Professor Nelson, Stacy Miller, and Megan Reilly in the trial court, alleging breach of contract, defamation, and intentional infliction of emotional distress (IIED).
- The defendants filed preliminary objections, which the trial court sustained.
- Reardon filed an amended complaint which added a new negligence claim.
- The defendants again filed preliminary objections in the nature of a demurrer to all counts of the amended complaint.
- The trial court sustained the defendants' preliminary objections and dismissed Reardon's amended complaint with prejudice.
- Reardon, as appellant, appealed the trial court's dismissal to the Superior Court of Pennsylvania, an intermediate appellate court.
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Issue:
Does a private college breach its contract with a student by conducting a disciplinary proceeding that the student alleges was biased, if the college follows the express procedural rules set forth in its student handbook?
Opinions:
Majority - Tamilia, J.
No. A private college does not breach its contract with a student if it provides the procedural safeguards promised in its student handbook, and courts will not intervene to assess the fairness or outcome of such internal decisions. The relationship between a student and a private college is purely contractual, defined by documents like the student handbook. Here, Allegheny College afforded Reardon the rights promised in The Compass, including notice and an opportunity to be heard. Her complaints about procedural irregularities—such as alleged bias, improper attendees at meetings, and failure to gather exculpatory evidence—do not constitute a breach because these specific issues were not governed by the express terms of The Compass. Because The Compass states that the President's decision is final, and the college did not breach the unambiguous terms of the agreement, the court is precluded from reviewing the merits of the college's private, internal decisions. The court also dismissed Reardon's other claims, finding the defamation claim failed because the statements were opinions or factually true, the negligence claim was barred by the 'gist of the action' doctrine as it merely restated the contract claim, and the IIED claim failed as the conduct was not sufficiently outrageous.
Analysis:
This decision reinforces the principle of judicial non-interference with the internal disciplinary proceedings of private academic institutions. It solidifies the view that the student-university relationship is strictly contractual, limiting a student's recourse to the express terms of the student handbook. The court's application of the 'gist of the action' doctrine is also significant, as it prevents plaintiffs from recasting a breach of contract claim as a tort claim (like negligence) to gain procedural advantages or access to different damages, thereby protecting the distinction between contract and tort law.
