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University’s Website Guarantee Subjected School To Breach Of Contract Claim
Jimmy Smith, an African American student enrolled at Roger Williams University Law School in the Fall of 2016, alleged that, due to his race, the University took adverse actions against him.
Smith argued that he had been outspoken on racial issues since 2016, and when he talked about issues of race in class, his white classmates complained, and he was called by the School’s Title IX coordinator to talk about the issue. Smith did not offer details of the resulting discussions but noted that they did not result in any disciplinary action against him. Smith argued that these meetings were not held when he complained about white classmates. Smith also alleged that the University dismissed a disciplinary complaint he filed against a white female student, but the University did not dismiss the disciplinary proceedings against him brought by the same student. He also claimed that the School commenced disciplinary proceedings against him only after the sole African American on the disciplinary board contracted COVID-19.
Finally, Smith argued that he was denied an opportunity to participate in the University’s clinical program because of a “run-in” with the law, while white students with legal issues were not denied those opportunities, and while white faculty members have not been disciplined for their legal struggles. He alleged that the University “guaranteed” students a clinical placement on its website.
The Court found that Smith’s discrimination claims were not pled with facts sufficient to support a plausible claim of racial discrimination. Each claim alleges that Smith was treated differently than white students and given harsher punishments than white students, but the complaint contains only conclusory allegations, without further explanation. The Court noted that since Smith was involved in these situations, he had more details within his control that he could share, but declined to do so. For example, Smith failed to show that the University treated a comparator group (i.e., white students) differently despite similar conduct.
As for Smith’s breach of contract claim, the Court found that although there was no indication in the Student Handbook that students were guaranteed clinical placement, there was a page on the University’s website titled, “The Clinical Guarantee.” Included on this page, in large font, was the statement that “RWU Law guarantees that every qualified student will be afforded a substantial, hands-on clinical experience.” Then, at the bottom of the page, there was a bullet point that said, “WE GUARANTEE IT.” In light of this language, the Court denied the University’s motion to dismiss the breach of contract claim. The Court noted that even with the language that this was only a guarantee for “qualified students,” that matter will need to be decided on its merits.
The Court dismissed Smith’s discrimination claims but allowed the breach of contract claim to proceed.
Smith v. Roger Williams University Law School (D.R.I., Feb. 16, 2023) 2023 WL 2048257.
Note: The relationship between a student and a private school is contractual. This case serves as an important reminder that the terms of that contractual relationship are not just based on a school’s handbooks and enrollment agreement, but also on other information such as statements and promises on a school’s website.