Steinberg v. Chicago Medical School
371 N.E.2d 634, 13 Ill. Dec. 699, 69 Ill. 2d 320 (1977)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A university's distribution of a catalog or bulletin describing its admissions criteria constitutes an invitation for an offer, and an applicant's submission of an application and fee constitutes an offer; the university's acceptance of the application and fee forms an enforceable contract obligating it to evaluate the applicant according to those stated criteria.
Facts:
- Chicago Medical School distributed a bulletin for the 1974-75 academic year to prospective students.
- The bulletin stated that applicants would be selected based on scholarship, character, motivation, academic achievement, test results, and personal appraisals.
- After receiving the bulletin, Robert Steinberg applied for admission to the school.
- Steinberg paid the required $15 application fee.
- The Chicago Medical School accepted Steinberg's application and fee for consideration.
- Steinberg alleged that the school did not evaluate his application based on the published criteria, but instead used nonacademic criteria, primarily the applicant's ability to make or pledge large monetary contributions.
- Steinberg was rejected for admission.
Procedural Posture:
- Robert Steinberg filed a four-count class action complaint against Chicago Medical School in the Circuit Court of Cook County, an Illinois trial court.
- The trial court granted the school's motion to dismiss the entire complaint for failure to state a cause of action.
- Steinberg, as appellant, appealed the dismissal to the Illinois Appellate Court, an intermediate appellate court.
- The appellate court reversed the dismissal of the breach of contract claim (Count I) but affirmed the dismissal of the other three counts (Consumer Fraud, Fraud, and Unjust Enrichment).
- Both parties appealed to the Supreme Court of Illinois, the state's highest court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does an applicant's submission of an application and fee, in response to a university's bulletin describing its evaluation criteria, create an enforceable contract that is breached when the university uses undisclosed criteria to make its admissions decisions?
Opinions:
Majority - Mr. Justice Dooley
Yes, an enforceable contract is created, and using undisclosed criteria constitutes a breach of that contract. The school's bulletin was an invitation for an offer, Steinberg's application and payment of the fee was an offer, and the school's acceptance of the application and fee was an acceptance of that offer. The $15 fee served as sufficient consideration to form a binding contract. This contract obligated the school to evaluate Steinberg's application according to the criteria it had published, not to admit him. The court reasoned that while a merchant's advertisement is typically an invitation to deal, taking the customer's money constitutes acceptance of an offer to purchase on the advertised terms; similarly, the school's acceptance of the fee bound it to the terms in its brochure. The court also revived Steinberg's fraud claim, finding that a false representation of future conduct (the promise to use certain criteria) can be fraudulent if it is part of the scheme used to accomplish the fraud. Finally, the court held that the case was suitable for a class action under a new Illinois statute, as there are common questions of law and fact that predominate over individual issues.
Analysis:
This case is significant for establishing that the relationship between a university and an applicant is contractual in nature. By treating the university's catalog as part of a binding agreement, the decision holds educational institutions accountable for the promises made in their promotional and official materials. It moves away from the idea that private universities have unlimited discretion in their admissions processes, instead subjecting their published procedures to judicial review for breach of contract and fraud. This precedent impacts how universities draft their admissions materials and creates a cause of action for applicants who believe they were evaluated based on criteria other than what was publicly stated.
