Melissa Luong was a doctoral student in Vanderbilt University’s Community Research & Action (CRA) Ph.D. Program. Prior to the 2024-25 academic year, Luong maintained a 4.0 GPA, received positive annual evaluations, and performed well in her teaching assistant responsibilities. During the 2024-25 academic year, however, Luong began experiencing significant mental-health and medical conditions that affected her ability to concentrate, sleep, and meet academic expectations. She informed her faculty advisor after canceling several meetings due to health concerns and later received diagnoses of major depression, anxiety disorder, and post-traumatic stress disorder.
In early 2025, Luong sought accommodations through Vanderbilt’s Student Access Office (SAO). While the SAO recognized that Luong had qualifying disabilities, it declined to provide accommodations related to advisor expectations or research deadlines, determining that such matters were academic in nature and should be addressed through the department. The SAO approved only notetaking support. Luong then contacted department leadership and graduate support offices, requesting assistance with modifying deadlines, resolving her advising relationship, and ultimately switching advisors. Despite these efforts, Luong did not receive approval for her requested accommodations or assistance in identifying a new advisor.
During the spring of 2025, Luong’s academic progress continued to lag. Vanderbilt faculty documented that she had not met several program benchmarks, including timely submission of required written work and completion of coursework listed in her program of study. In July 2025, Vanderbilt dismissed Luong from the CRA Program, citing inadequate progress toward her Ph.D. degree and her failure to establish a new advising relationship.
Luong appealed the dismissal through Vanderbilt’s internal appeals process. While her first two appeals were denied, a third appeal was partially granted after the University acknowledged that the CRA Program failed to provide proper notice of deadlines and did not fully follow published procedures. Vanderbilt conditionally reinstated Luong, but only if she independently secured a new faculty advisor by a specified deadline. The University declined to assign an advisor on her behalf, explaining that advising relationships require mutual agreement and cannot be imposed administratively. When Luong was unable to secure a new advisor, her dismissal effectively stood.
Luong then filed suit in federal court alleging disability discrimination and failure to accommodate under Section 504 of the Rehabilitation Act and the Americans with Disabilities Act (ADA), retaliation for requesting accommodations and pursuing appeals, and breach of contract based on alleged violations of Vanderbilt’s student handbook and academic policies. She moved for a temporary restraining order and preliminary injunction seeking reinstatement to the Ph.D. program, assignment of a new advisor, restoration of funding and benefits, and access to her educational records.
The trial court denied the motion in full. Applying the traditional four-factor standard for injunctive relief, the Court concluded that Luong failed at the threshold requirement of demonstrating a likelihood of success on any of her claims. With respect to her failure-to-accommodate claim, the Court held that Luong did not establish that her requested accommodations were objectively reasonable. The Court emphasized that universities are entitled to deference in academic matters and are not required to lower academic standards or substantially alter core components of doctoral programs, including faculty-advisor relationships and research expectations.
The Court also rejected Luong’s claim that her dismissal was discriminatory. The record showed that Vanderbilt dismissed her for lack of academic progress and failure to meet program requirements, not because of her disability. Although Luong argued that any lack of progress resulted from Vanderbilt’s refusal to accommodate her, the Court found this argument unpersuasive given her failure to show that the requested accommodations were reasonable in the first place.
Luong’s retaliation claim similarly failed. The Court found that the timing of events did not support an inference of retaliatory motive and that Luong relied almost entirely on temporal proximity without additional evidence of retaliatory conduct. Finally, the Court rejected Luong’s breach-of-contract claim, concluding that even if the student handbook created contractual obligations, Luong’s failure to meet essential academic requirements likely constituted a material breach excusing further performance by the University.
Because Luong failed to demonstrate a likelihood of success on the merits, the Court declined to grant emergency injunctive relief and denied her motion in its entirety.
Luong v. Vanderbilt Univ. (M.D.Tenn. Dec. 3, 2025) 2025 LX 522883.
Note: This case underscores the importance of clearly documenting academic expectations, accommodation decisions, and adherence to published procedures, especially when academic dismissal decisions intersect with disability accommodation requests.