Joshua Carter enrolled in the University of Missouri-Kansas City’s (“UMKC”) joint B.A./M.D. program in 2011. The accelerated program was designed to allow students to earn a medical degree in six years. During the summer after his first year, Carter received a “D” in Cell Biology, a course required to advance later in the program. UMKC informed him that he would be placed on an Alternative Curriculum Plan (“ACP”), which would extend the six-year program by an additional year.
Carter immediately objected, pointing to provisions in the Program’s Policy Manual that he believed permitted him to continue on the regular track subject to academic probation. UMKC nevertheless required him to accept the ACP as a condition of remaining in the Program. The ACP required Carter to retake Cell Biology and another course he had already passed, as well as complete three additional biology electives. According to Carter, the assistant dean told his father that the ACP would help “bolster” Carter’s science GPA, which had to remain at or above 2.80 for Carter to stay in the Program.
Carter performed well under the ACP, earning an “A” in all five courses. He expected those grades to improve his science GPA based on two representations from UMKC. First, the Program’s Manual expressly stated that when a student repeated a science course, “only the final grade” would be used in calculating the student’s science GPA. Second, Carter alleged that the email containing his ACP stated that the three additional biology electives would count toward his science GPA.
UMKC subsequently told Carter that it would not calculate his GPA as he expected. His original grade in one repeated course would remain because it was not eligible for grade replacement; the three biology electives would not count toward his science GPA; and his original and new Cell Biology grades would be averaged rather than replacing the original grade. Carter later fell below the Program’s required 2.80 science GPA and was told that he could repeat his second-year coursework or leave the Program. He withdrew and eventually graduated from UMKC with an undergraduate biology degree. Carter alleged that, had UMKC calculated his GPA as promised, he would have remained above the required threshold and continued toward his medical degree.
Carter sued UMKC, asserting several breach-of-contract theories. In addition to the GPA calculation, he alleged that UMKC breached contractual obligations by improperly requiring him to participate in the ACP, failing to separately report undergraduate and medical-school GPAs on his transcript, and misrepresenting that the entire six-year program was accredited as medical-school education. The trial court dismissed his claims, and Carter appealed.
The Missouri Court of Appeals explained that a university’s promises to its students can create contractual obligations when they are sufficiently specific. Those promises need not necessarily appear in a traditional signed contract: brochures, policy manuals, advertisements, and other university materials may form part of the contractual relationship between a student and the institution. At the same time, not every representation is enforceable. A student must identify a particular contractual promise that the university failed to honor; general or aspirational statements ordinarily are insufficient.
Applying that distinction, the Court held that Carter had sufficiently alleged a breach based on the grade-replacement provision in the Program’s Manual. Unlike a general promise to support students academically, the Manual provided a concrete mechanism: if a student repeated a science course, only the final grade would be used in calculating the science GPA. The Court characterized this as an “objective, specific, and express representation” sufficiently concrete to support a contractual promise.
The Court reached the same conclusion regarding the email containing Carter’s ACP. According to Carter, that communication specifically represented that the three biology electives UMKC required him to take would count toward his science GPA. Because that was a promise that UMKC would take a concrete, identifiable action if Carter completed the courses, it too could support a contract claim. By contrast, the assistant dean’s more general statement that the ACP would “bolster” Carter’s GPA did not identify any particular action UMKC promised to take and was therefore too aspirational to constitute an enforceable promise.
The Court rejected Carter’s other contract theories. His claim that the entire B.A./M.D. Program was represented as accredited failed because he could not identify a specific promise that the first two years themselves would constitute accredited medical-school education or that every course would count directly toward his M.D. degree. The fact that the Program was marketed as an accelerated B.A./M.D. program created an expectation that some coursework would count toward each degree, not that all six years constituted accredited medical-school coursework.
The Court similarly rejected Carter’s reliance on the Program’s higher tuition. It distinguished an earlier COVID-era case in which a university offered separate online and in-person programs at different prices, which supported an inference that students paying the higher price had been promised an in-person experience. Here, Carter acknowledged receiving the features that distinguished UMKC’s accelerated program, including early clinical experience, access to medical-school coursework while still an undergraduate, and a pathway to completing both degrees in six years. The higher price therefore did not itself establish an implied promise that the first two years were accredited as medical-school education.
The Court emphasized that it was deciding only whether Carter had sufficiently alleged contractual promises at the pleading stage, not whether UMKC actually breached those promises or whether Carter would ultimately prevail.
Carter v. Curators of the Univ. of Mo. (Ct.App. Aug. 4, 2026) 2026 WL 2233843.
Note: School policies and individualized communications can potentially create contractual obligations when they describe a specific action the school promises to take. Schools should review handbooks, enrollment materials, academic policies, and communications to families for language that may unintentionally limit a school’s discretion.