Board of Curators of the University of Missouri v. Horowitz

PETITIONER: Board of Curators of the University of Missouri
RESPONDENT: Charlotte Horowitz
LOCATION: University of Missouri- Kansas City

DOCKET NO.: 76-695
DECIDED BY: Burger Court (1975-1981)
LOWER COURT: United States Court of Appeals for the Eighth Circuit

CITATION: 435 US 78 (1978)
ARGUED: Nov 07, 1977
DECIDED: Mar 01, 1978

ADVOCATES:
Arthur A. Benson, II - for respondent
Marvin E. Wright - for petitioners

Facts of the case

Several faculty members of the University of Missouri-Kansas City Medical School expressed dissatisfaction with the clinical performance of Charlotte Horowitz, a medical student. The Council of Evaluation (Council), a faculty-student body that recommends various actions including probation and dismissal, recommended Horowitz only advanceto her last year on a probationary status. In the middle of the following academic year, the Council concluded that Horowitz should not be considered for graduation at the end of the year and would be dropped as a student unless the Council saw a radical improvement. Horowitz failed to show improvement, her surgery rotations rated “low satisfactory,” and the Council recommended dismissal from the university. A committee composed solely of faculty members and the Dean, the final decision-makers, approved the decision. Horowitz sued and claimed that the procedure leading to her dismissal violated the Due Process Clause of the Fourteenth Amendment. The district court concluded that Horowitz had been afforded all the rights guaranteed by the Fourteenth Amendment. The U.S. Court of Appeals for the Eighth Circuit reversed the decision by holding that Horowitz had not been afforded procedural due process prior.

Question

Does an academic dismissal from a university without a hearing before the school’s decision-making body violate the Due Process Clause of the Fourteenth Amendment?

Media for Board of Curators of the University of Missouri v. Horowitz

Audio Transcription for Oral Argument - November 07, 1977 in Board of Curators of the University of Missouri v. Horowitz

Audio Transcription for Opinion Announcement - March 01, 1978 in Board of Curators of the University of Missouri v. Horowitz

Warren E. Burger:

The judgments and opinion of the court in 76-695 Board of Curators of University of Missouri against Horowitz which will be announced by Mr. Justice Rehnquist.

William H. Rehnquist:

In this the petitioner, the University of Missouri dismissed respondent, Charlotte Horowitz from its Medical School because of academic deficiencies.

The decision to dismissal was made by the medical school's council of evaluation after examining for academic performance over a two year period including one year of probation.

She sued petitioners alleging that the university had deprived her of procedural and substantive due process by dismissing her.

The District Court for the Western District of Missouri after a full trial concluded that she had been afforded all rights guaranteed her by the Fourteenth Amendment.

The Court of Appeals for the Eight Circuit to what she appealed disagreed holding that she had been denied procedural due process.

In an opinion filed today with the clerk of the court, we reverse the Court of Appeals, assuming that the respondent had a liberty of property interest and receded the medical school.

We concluded that the university gave her adequate procedural due process, before the dismissing.

Academic dismissals do not necessitate the same sort of procedures as due disciplinary dismissals.

We also conclude that she was not been deprived of substantive due process.

Even assuming that Federal Courts can review under narrow standards of the validity of an academic decision by a public educational institution.

The District Court expressly found that respondent's dismissal was not arbitrary or capricious.

Mr. Justice Powell while joining the opinion of the court.

He has also filed the concurring opinion.

Mr. Justice White has filed an opinion concurring in part and concurring in the judgment.

Mr. Justice Marshall has filed an opinion concurring in part and dissenting in part.

Mr. Justice Blackmun joined by Mr. Justice Brennan has filed an opinion concurring in part and dissenting in part.

Warren E. Burger:

Thank you Mr. Justice Rehnquist.