Brandon Meng, a medical student at William Carey University’s College of Osteopathic Medicine, filed suit after a disciplinary incident led to his removal from campus and ultimately his inability to continue in the program. Meng, a Canadian citizen of Chinese ethnicity, alleged that the University and its administrators discriminated against him, breached contractual obligations, and effectively forced him to withdraw following a confrontation with a professor.
The dispute began in September 2023, when Meng missed a class due to nausea and flu-like symptoms and exchanged communications with a pathology professor regarding his absence. According to Meng, those communications escalated, with the professor suggesting that he be tested for tuberculosis. Concerned that such a diagnosis could significantly delay his studies, Meng went to the professor’s office that evening to discuss the issue. During that meeting, Meng alleged that the professor accused him of having tuberculosis without medical evidence and that the conversation became confrontational. Meng also questioned whether the professor’s conduct was influenced by his Chinese background.
Following the incident, the professor reported the interaction to University leadership, allegedly describing Meng as unstable and potentially threatening. Within a short period of time, the Dean had Meng escorted off campus by security before any formal disciplinary proceedings had occurred. The University then initiated its disciplinary process under the Student Affairs Committee, which held two separate hearings on allegations of unprofessional conduct.
After both hearings, the Committee recommended that the matter be dismissed. However, the Dean exercised his authority as the final decisionmaker and issued a “Non-Academic Warning” to Meng for the remainder of the academic year. The warning outlined expectations for future conduct and directed Meng on how to resume his studies. Meng alleged that, despite these instructions, subsequent communications from University officials were inconsistent and left him uncertain how to return, and that the combination of the disciplinary action and academic requirements ultimately prevented him from completing the program within the required six-year timeframe.
Meng asserted a wide range of claims, including discrimination under Title VI and multiple breach of contract theories based on the student handbook.
The Court dismissed all claims. With respect to the Title VI discrimination claim, the Court emphasized that the statute requires allegations of intentional discrimination. The Court found that Meng relied primarily on his subjective belief that the professor’s actions were motivated by his ethnicity, without identifying any statements or conduct that plausibly suggested discriminatory intent. The professor’s communications about a potential medical condition and prior allegedly rude comment that Meng reminded him of another classmate did not reference Meng’s race or national origin and thus did not support an inference of discrimination.
Meng’s breach of contract claims likewise failed. Although Mississippi law recognizes that a student-university relationship can have contractual aspects, the Court found that the University’s student handbook expressly disclaimed any intent to create a binding contract. Because the handbook stated that it did not constitute a legally binding agreement, Meng could not rely on its provisions as enforceable contractual terms.
The Court further held that, even under an implied contract theory, Meng failed to state a claim. Courts afford private universities significant discretion in disciplinary matters, and the relevant question is whether the process was fundamentally fair and not arbitrary or capricious. Here, Meng received notice of the allegations, participated in multiple hearings, and had an opportunity to present his version of events. The fact that the Dean reached a different conclusion than the committee did not render the process unfair.
Accordingly, the Court granted the defendants’ motions to dismiss.
Meng v. William Carey University (S.D. Miss. 2026) 2026 WL 147539.
Note: This case highlights that in handling student discipline matters, the process should be fundamentally fair, which includes providing a student with notice of the charges and an opportunity to respond. Because the University met that standard, the fact that the Dean reached a different conclusion than the committee did not render the process unfair.