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Cencor, Inc. v. Tolman

Citations: 868 P.2d 396; 1994 WL 32186Docket: 92SC821

Court: Supreme Court of Colorado; February 28, 1994; Colorado; State Supreme Court

Narrative Opinion Summary

The case involves a legal dispute between a Delaware corporation operating as a college and its former students who alleged various claims, including negligence, misrepresentation, and breach of contract. The students sought compensatory and exemplary damages, arguing that the college failed to deliver promised educational services. The trial court granted summary judgment in favor of the college, dismissing negligence claims as educational malpractice, which is not recognized in Colorado, and finding no factual basis for other claims. On appeal, the court affirmed the dismissal of negligence claims but reversed the summary judgment on contract and misrepresentation claims, citing material factual disputes. These claims were remanded for further proceedings. The appellate court emphasized the contractual nature of the student-college relationship, allowing breach of contract claims regarding specific promises like training and instruction hours to proceed. The case highlights the distinction between viable contract claims and non-recognizable educational malpractice claims. The court denied the college's petition for certiorari, affirming the appellate decision, and noted that some plaintiffs' claims were dismissed for discovery noncompliance and others voluntarily dismissed certain claims.

Legal Issues Addressed

Breach of Contract in Educational Settings

Application: The court allowed breach of contract claims to proceed where specific educational services promised in enrollment agreements were allegedly not delivered.

Reasoning: Claims asserting a failure to deliver specifically promised educational services, such as class offerings or required instruction hours, are valid under contract law.

Educational Malpractice Not Recognized in Colorado

Application: The court determined that claims of negligence related to educational quality fall under educational malpractice, which is not a recognized theory in Colorado.

Reasoning: The court concluded that the negligence claims amounted to educational malpractice, a theory not recognized in Colorado.

Evaluation of Summary Judgment Motions

Application: In assessing a motion for summary judgment, the court emphasized that factual inferences must favor the non-moving party, and the moving party carries the burden to show no genuine issue of material fact exists.

Reasoning: In evaluating summary judgment motions, all factual inferences must favor the non-moving party, and the burden rests on the moving party to demonstrate no genuine issue of material fact exists.

Material Factual Disputes in Contract Claims

Application: The court identified unresolved factual disputes in breach of contract claims concerning the delivery of educational services, highlighting the necessity for factual determinations by a trier of fact.

Reasoning: The respondents' interrogatory responses indicate material factual disputes regarding the breach of contract claim in the sixth claim for relief. These disputes are to be resolved by the trier of fact.