Tedeschi v. Wagner College
No Reporter Information Available (1980)
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Rule of Law:
When a private university has adopted a rule or guideline establishing the procedure to be followed for student suspension or expulsion, that procedure must be substantially observed.
Facts:
- In the fall of 1976, Nancy Jean Tedeschi, a student at Wagner College, exhibited disruptive behavior in her Latin class taught by Dr. Thompson, frequently leaving and re-entering the room.
- On December 20, 1976, at the conclusion of her Latin final exam, Tedeschi tore up her exam booklet and did not submit it.
- Over the next two days, Tedeschi subjected Dr. Thompson to a series of harassing telephone calls, in which she threatened to commit suicide and to "fix" him, and she also appeared at his home in a distraught state.
- On January 10, 1977, college officials attempted to arrange a meeting with Tedeschi and her mother to discuss her academic situation, but Tedeschi refused, stating there was no problem.
- Tedeschi's mother also refused to meet with college officials and insisted that any issues be communicated in a formal letter.
- The following day, Tedeschi was orally informed of her suspension, and on January 13, 1977, she received a letter formally advising her that she was "withdrawn from classes for the 1977 spring semester."
Procedural Posture:
- Nancy Jean Tedeschi filed an action against Wagner College in the New York Supreme Court, Richmond County (trial court).
- The trial court found in favor of Wagner College, concluding that the college had acted in good faith and was not arbitrary.
- Tedeschi, as appellant, appealed the judgment to the Appellate Division of the Supreme Court (intermediate appellate court).
- A divided Appellate Division affirmed the trial court's judgment for Wagner College, the appellee.
- Tedeschi, as appellant, then appealed to the Court of Appeals of New York, the state's highest court.
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Issue:
Does a private college's failure to follow its own published procedural guidelines for a non-academic student suspension entitle the student to judicial relief?
Opinions:
Majority - Meyer, J.
Yes. When a university has adopted a rule or guideline establishing the procedure to be followed in relation to suspension or expulsion, that procedure must be substantially observed. Wagner College's own guidelines grant a student the right to a hearing before the Student-Faculty Hearing Board if suspended for any cause other than academic failure. Tedeschi's suspension was, at least in part, for non-academic reasons such as her disruptive and harassing conduct. Therefore, the college was bound to follow its own rules and provide her with the prescribed hearing. The informal meetings offered by the administration did not constitute an acceptable substitute for the formal hearing procedure outlined in the college's guidelines, and the college had an affirmative obligation to inform her of this right.
Dissenting - Gabrielli, J.
No. Requiring the college to adhere to its formal hearing procedures in this case elevates formal legalistic principles over common sense. Tedeschi's suspension was a result of her emotional instability and inability to function in an academic setting, making it a matter of academic discretion. The college officials acted fairly and attempted to resolve the issue informally, which Tedeschi and her mother rebuffed. Given that the facts of her behavior were not in dispute and her conduct indicated she was not interested in presenting her side of the story, forcing a formal hearing years later would be a futile and meaningless exercise.
Analysis:
This decision establishes that private universities in New York are bound by the terms of their own student handbooks and guidelines, creating an enforceable duty. The court grounds this obligation in principles of contract law, the law of associations, and fundamental fairness, extending procedural protections to students in private institutions for non-academic disciplinary matters. This precedent gives students a basis for judicial review when a private school fails to follow its own published rules, moving beyond a simple inquiry into whether the school acted in good faith to a more rigorous standard of procedural compliance.
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