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Liu v. Northwestern University

Citations: 78 F. Supp. 3d 839; 2015 U.S. Dist. LEXIS 8751; 2015 WL 328213Docket: No. 14 C 4993

Court: District Court, N.D. Illinois; January 25, 2015; Federal District Court

Narrative Opinion Summary

This case involves a former law student who filed a fifteen-count complaint against Northwestern University and its Associate Dean, citing violations of the Americans with Disabilities Act, the Rehabilitation Act, and several state law claims. The central issues include allegations of breach of contract concerning university policies, particularly due process protections outlined in the student handbook, defamation, public disclosure of private facts, and tortious interference with contractual relations. The court allowed the breach of contract claim to proceed concerning allegations of due process violations but dismissed claims related to the timeframe for grievance investigations. Defamation claims were dismissed as the statements were deemed nonactionable opinions, and the public disclosure claim failed to demonstrate any private facts were made public. The tortious interference claim was also dismissed, as the physician-patient relationship was considered terminable at will. The court's decision partially granted and partially denied the defendants' motion to dismiss, requiring a response to remaining allegations by a specified date.

Legal Issues Addressed

Americans with Disabilities Act and Rehabilitation Act Claims

Application: The plaintiff alleged violations of the ADA and Rehabilitation Act, which were not addressed in the defendants' motion to dismiss.

Reasoning: Annie Liu, a former law student at Northwestern University, has filed a fifteen-count complaint against Northwestern University and Clifford Zimmerman, the Associate Dean of the law school, alleging violations of the Americans with Disabilities Act (ADA) and the Rehabilitation Act, alongside various state law claims.

Breach of Contract under University Policies

Application: The plaintiff's claim for breach of contract was allowed to proceed concerning due process procedures in the student handbook, but dismissed regarding the timeframe of grievance investigations.

Reasoning: The court allows Liu's breach of contract claim regarding due process procedures in the student handbook to proceed but dismisses her claim about the timeframe of grievance investigations, as no specific timeframe was mandated.

Defamation and Opinion

Application: The court dismissed the defamation claim, finding that the statements in question were nonactionable opinions rather than factual assertions.

Reasoning: Liu's defamation claim is dismissed because Zimmerman’s statements are deemed nonactionable opinions.

Public Disclosure of Private Facts

Application: The claim was dismissed due to a lack of plausible allegations regarding any private information being disclosed publicly.

Reasoning: Her claim for public disclosure of private facts fails due to a lack of plausible allegations regarding any private information disclosed.

Tortious Interference with Contract

Application: The court dismissed the claim, noting the terminable-at-will nature of the physician-patient relationship under Illinois law.

Reasoning: Additionally, her tortious interference claim is dismissed because her relationship with her psychiatrist was terminable at will.