Rhoma Mirza, a Pakistani-American Muslim student, began the Physician Assistant (PA) Program at the College of Mount St. Vincent in 2022. In September 2023, she submitted a letter of recommendation for a friend through a centralized application system, signing the letter as “Rohma Mirza, PA-C.” This designation stands for “Physician Assistant—Certified” and is reserved for graduates who have passed the national certifying exam and hold a license.
The student handbook clearly stated that PA students must identify themselves as “PA Student” or “PA-S” and are prohibited from misrepresenting themselves as certified physician assistants (PA-C). It further warned that misrepresentation of credentials—such as using the PA-C designation—constituted a serious ethical violation that could result in dismissal from the program, even without prior disciplinary history.
The College viewed Mirza’s signature as a misrepresentation of credentials and referred the matter to its Professional Conduct Review Committee (PCRC), which found the act to be an ethical violation. In accordance with the discipline policy outlined in the student handbook, the matter proceeded through four levels of review, including the PCRC, the Academic Progress Committee (APC), the PA Program Director, and the Provost. At each stage, the decision to dismiss Mirza from the program was upheld.
Mirza sued and argued that the signature was an innocent mistake, possibly the result of a template or confusion about the acronym, which she claimed she thought stood for “PA Candidate.” She asserted that the error was harmless, quickly corrected, and did not mislead anyone. She further alleged that the disciplinary proceedings were tainted by religious and ethnic bias and that administrators, particularly one faculty member, harbored anti-Muslim and anti-Pakistani sentiments. Mirza claimed she had been singled out for disciplinary action due to her background and advocacy for her classmates.
Article 78 proceedings are legal actions in New York that are used to challenge the actions of administrative bodies or public (or quasi-public) institutions. In Mirza’s Article 78 proceeding, she sought an order declaring the expulsion arbitrary and capricious, mandating her reinstatement, awarding damages, and granting declaratory and injunctive relief. She also asserted several additional civil causes of action, including breach of contract, civil rights violations under 42 U.S.C. sections 1981, 1985, and 1986, and defamation.
The Court began by emphasizing the narrow role of judicial review in academic disciplinary decisions by private colleges. It reaffirmed that courts may not substitute their judgment for that of school officials unless the disciplinary action is clearly arbitrary, capricious, or in bad faith, or if the college fails to follow its own procedures. The Court found that, here, the College had substantially complied with its internal policies as set forth in the student handbook, which explicitly warns that misrepresentation of PA status is grounds for dismissal. The Court noted that Mirza had been notified of the proceedings, had participated in the initial hearing, had the opportunity to appeal, and failed to attend the APC hearing, despite receiving notice. Her appeals to the program director and the provost were fully considered and denied based on the seriousness of the ethical breach.
The Court rejected Mirza’s argument that she was denied due process. It explained that private colleges are not required to provide constitutional due process, but rather must substantially adhere to their own published procedures. The College’s refusal to reschedule the hearing Mirza missed was consistent with its stated policies. The Court also dismissed the argument that the penalty of expulsion was so excessive as to “shock the conscience.” While it acknowledged the severity of the outcome and the personal investment Mirza had made in her education, the Court found that the sanction was proportionate to the ethical violation in a profession where misrepresentation of credentials carries significant consequences. The decision to expel her was supported by multiple levels of academic judgment and did not warrant judicial intervention.
The Court also dismissed Mirza’s civil rights claims under federal statutes. Her allegations of a conspiracy to violate her rights under 42 U.S.C. sections 1985 and 1986 were found to be conclusory and unsupported by factual evidence. The Court emphasized that there was no proof of a “meeting of the minds” or coordinated action among faculty members to discriminate against her.
42 U.S.C. Section 1981 guarantees equal rights under the law, specifically the right to make and enforce contracts without discrimination based on race, color, or ethnicity. The Court determined that Mirza’s claim under Section 1981 failed because she did not clearly allege racial discrimination, and the statute does not protect against discrimination based on religion or national origin. The Court noted that no similarly situated students were identified who received different treatment.
Her breach of contract claim was also dismissed. The Court held that they were duplicative of her Article 78 claims and therefore could not be pursued separately. Even if they were considered on their merits, the Court found that the College had complied with the student handbook, and that Mirza had not fulfilled her obligations under the alleged contract due to her ethical violation.
Finally, the Court rejected the defamation claim. The statements at issue were made within the College’s internal disciplinary process, had not been published externally, and were protected by a qualified common interest privilege. The Court held that Mirza’s allegations of malice were insufficient to overcome that privilege.
The Court concluded by denying all of Mirza’s requested relief, including reinstatement, damages, and declaratory relief. It granted the College’s motion to dismiss the entire Article 78 petition and civil complaint and entered judgment in the College’s favor.
Mirza v. Coll. of Mount Saint Vincent, 2025 NYLJ LEXIS 943.
Note: This decision reinforces the importance for schools to follow their policies, including those related to discipline and conduct. In California, private schools must afford a student accused of serious misconduct with fair procedure, which includes notice of the charges and a meaningful opportunity to be heard.