Chapman University, like many institutions, closed its campus in March 2020 and moved to online instruction following public health orders related to the COVID-19 pandemic. In the months leading up to the Fall 2020 semester, Chapman communicated with students about the possibility of reopening campus, stating that its “goal” was to offer some in-person instruction and that it remained “optimistic,” while also making clear that any return depended on governmental “support and approval.” When those approvals did not materialize, Chapman informed students it would proceed with remote instruction. The plaintiffs, two students, remained enrolled and ultimately graduated.
Nonetheless, the two students sued, asserting claims for breach of contract, unjust enrichment, and unfair business practices, arguing that Chapman had promised in-person education and should have provided partial tuition refunds. They relied on various University materials, including course registration listings showing classroom locations, policies referencing “face-to-face contact,” faculty handbook language about on-campus teaching and availability, descriptions of high-end campus facilities in the University’s catalogs, and the University’s longstanding practice of offering in-person instruction. They argued that these materials created an enforceable implied contract to provide in-person instruction.
The Court rejected these claims and affirmed summary judgment for Chapman. It emphasized that under California law, an implied contractual promise in the student-university context must be based on specific and definite representations, not general expectations. Courts evaluate such claims by examining the parties’ reasonable expectations in light of all the circumstances, including the language used in publications and communications.
Applying that standard, the Court found that none of the materials cited by the students constituted a binding promise. Course listings reflected anticipated locations rather than guaranteed conditions, the catalogs expressly disclaimed contractual intent, and faculty handbook provisions were not directed to students. The Court also held that a University’s past practice of offering in-person instruction does not create a perpetual obligation to continue doing so.
The Court noted there was no evidence that Chapman offered a lower-cost, fully online version of the same program, which undercut the students’ argument that they paid for a premium in-person experience but received something materially different. The Court also found that Chapman’s communications about reopening, which described in-person instruction as a “goal” and expressing “optimism” subject to external approval, were aspirational and contingent, and therefore the opposite of specific promises.
The Court also rejected the students’ unjust enrichment and unfair business practices claims, concluding that the students received the benefit of their bargain by completing their coursework and earning degrees. Because no specific promise of in-person instruction existed, there was no basis for relief.
Grant v. Chapman University (2026) 118 Cal.App.5th 453.
Note: This case is an important reminder that courts may look to school publications, websites, handbooks, and communications to assess whether a school has made enforceable promises to students or families.