Haishan Yang, an international Ph.D. student at the University of Minnesota, sued several university officials after being expelled for academic dishonesty involving his use of artificial intelligence tools during a doctoral exam.
Yang was enrolled in the Health Services Research, Policy, and Administration program when, in August 2024, he took an eight-hour qualifying exam required for advancement in his program. The exam instructions explicitly prohibited the use of “any sort of Artificial Intelligence tools, such as ChatGPT.” After reviewing Yang’s exam, a faculty grading committee, including his professor, Dr. Hannah Neprash, concluded that his answers appeared inconsistent with his previous writing and contained ideas not covered in class. The committee compared Yang’s responses with ChatGPT outputs and found near-identical examples and phrasing, including several instances where his answers exactly matched AI-generated text. They also determined that he had likely used ChatGPT to draft practice exam responses.
Finding that the preponderance of the evidence showed unauthorized AI use, the committee referred the matter to the University’s Office for Community Standards (OCS). Yang met with OCS staff, submitted a 35-page written defense, and later participated in a formal hearing before the Campus Committee on Student Behavior—a five-member panel of faculty and students. Represented by an advocate, Yang was allowed to question witnesses, present evidence, and respond to the allegations. When his advocate attempted to generate new ChatGPT outputs during the hearing to challenge the University’s findings, the panel chair, Professor JaneAnne Murray, stopped the demonstration, explaining that the committee “does not create new evidence” during hearings.
At the conclusion of the hearing, the panel unanimously found Yang responsible for scholastic dishonesty. It cited the consistency of the evidence, the expert testimony of faculty members familiar with AI-generated writing, and Yang’s inconsistent explanations. The OCS imposed expulsion, which Yang appealed to Vice Provost Scott Lanyon. Lanyon affirmed the decision, finding it was supported by substantial evidence and concluding that Yang’s conduct undermined the University’s trust in the integrity of its academic process.
Yang’s expulsion caused the termination of his Student and Exchange Visitor Information System (SEVIS) record, resulting in the loss of his international student status and legal ability to remain in the United States. In January 2025, Yang filed a federal civil rights lawsuit under 42 U.S.C. §1983, alleging that the disciplinary process violated his constitutional rights to substantive and procedural due process. He sought over $4 million in damages, reinstatement to his Ph.D. program, and expungement of his disciplinary record.
Substantive due process protects individuals from arbitrary or irrational government action that “shocks the conscience.” In the academic context, a student must show that officials acted in bad faith or substantially departed from accepted academic norms. The Court found that Yang failed to make such a showing. Even assuming students have a constitutional right to continued education, the University’s decision was reasoned, evidence-based, and within the scope of professional academic judgment. The Court emphasized that universities are entitled to deference in academic discipline and that judicial intervention is warranted only in “truly egregious and extraordinary” circumstances.
Procedural due process guarantees notice and a fair opportunity to be heard before a person is deprived of a protected interest. Yang claimed the hearing process was biased and unfair, but the Court found that he had received detailed notice of the allegations, representation by an advocate, a full opportunity to present evidence, and appellate review, all of which satisfied due process. The Court also found that Yang’s procedural claims were premature because he had not yet exhausted all available remedies under Minnesota law.
The Court dismissed the case without prejudice.
Haishan Yang v. Neprash (D.Minn. Oct. 31, 2025) 2025 LX 416753.
Note: While this case involved a public university, it reflects principles similar to California’s “fair procedure” requirement for private schools: students facing serious discipline must receive notice of the charges and a meaningful opportunity to respond.