Narrative Opinion Summary
This case involves a dispute between a law school and the American Bar Association (ABA) over the accreditation of proposed satellite campuses. The law school alleged that the ABA denied due process by refusing to accredit these campuses and imposing sanctions for operating them without prior approval. The district court ruled in favor of the ABA, finding that due process was provided. The ABA's Council on Legal Education oversees the accreditation process, and the law school failed to obtain necessary approvals under ABA standards, leading to sanctions. The law school's claims under the Higher Education Act (HEA) were dismissed, as the HEA does not provide a private right of action. The court found that the ABA, as a quasi-public entity, must apply fair procedures and that its accreditation decision-making process did not violate due process. The court applied a standard of review for accreditation decisions based on administrative law principles, determining that the ABA's actions were neither arbitrary nor an abuse of discretion. The law school's arguments regarding procedural irregularities and sanctions were found meritless, and the district court's decision was affirmed. Additionally, the court noted that the law school waived its state law claims by failing to adequately argue them on appeal.
Legal Issues Addressed
Accreditation and Due Processsubscribe to see similar legal issues
Application: The court found that the ABA provided adequate due process to Cooley Law School during the accreditation process.
Reasoning: The district court ruled in favor of the ABA, concluding that Cooley received proper due process.
Common Law Duty of Fair Proceduressubscribe to see similar legal issues
Application: The ABA, as a quasi-public organization, has a duty to apply fair procedures in its accreditation decisions.
Reasoning: Many courts, including this one, have established that 'quasi-public' organizations, such as the ABA, have a common law duty to apply fair procedures in decisions affecting their members.
Higher Education Act (HEA) and Private Right of Actionsubscribe to see similar legal issues
Application: The court determined that the HEA does not provide a private right of action for institutions challenging accreditation decisions.
Reasoning: Cooley is barred from bringing a claim under the Higher Education Act (HEA) as the statute does not provide a private right of action.
Sanctions and Compliance under ABA Rulessubscribe to see similar legal issues
Application: The ABA's interpretation of its rules allowed for sanctions against Cooley despite its claims of compliance at the time of the hearing.
Reasoning: This interpretation refutes Cooley's argument that a school can fluctuate in compliance to evade sanctions.
Standard of Review for Accreditation Decisionssubscribe to see similar legal issues
Application: The court applies a common law standard to evaluate whether the ABA's accreditation decisions were arbitrary, unreasonable, or an abuse of discretion.
Reasoning: Several courts have established a standard of review for accreditation decisions, primarily relying on administrative law principles.