Alston v. Pennsylvania State University, 685 F. App'x 158

Alson Alston, a 50-year-old Penn State Law student (now graduated), sued Pennsylvania State University, its trustees, and several employees alleging denial of increased financial aid for transportation, personal health, and elder-care expenses.
He asserted federal claims under 42 U.S.C. § 1983 (Due Process and Equal Protection), the ADA, and the Rehabilitation Act, plus state-law claims.
Defendants moved to dismiss under Fed. R. Civ. P. 12(b)(6); the Magistrate Judge recommended dismissal, which the District Court adopted.
The District Court dismissed all federal claims with prejudice and declined supplemental jurisdiction over state-law claims, dismissing them without prejudice to pursue in state court.
Alston appealed pro se; the Third Circuit reviewed the dismissal de novo and applied the Iqbal/Twombly plausibility standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Due Process — substantive/procedural	Alston contended denial of increased aid deprived him of a protected interest without adequate process	Defendants argued financial aid at issue is not a constitutionally protected interest and no conscience-shocking conduct or lack of process was pleaded	Dismissed: no protected interest alleged; no facts showing arbitrary/conscience-shocking conduct or procedural deprivation
Equal Protection	Alston alleged disparate treatment in aid decisions	Defendants argued plaintiff failed to plead intentional differential treatment or lack of rational basis	Dismissed: Alston did not plead specific facts comparing similarly situated individuals or lack of rational basis
ADA/Rehabilitation Act discrimination	Alston claimed disability-based discrimination in denial of aid/ accommodations	Defendants argued complaint lacked facts linking defendants’ actions to any disability	Dismissed: Alston forfeited appellate challenge and complaint lacked facts showing actions were because of disability
Supplemental jurisdiction over state claims	Alston sought to keep state-law claims in federal court	Defendants argued dismissal of federal claims warranted declining supplemental jurisdiction	District Court properly declined supplemental jurisdiction and dismissed state claims without prejudice

Free Speech Coal., Inc. v. Attorney Gen. of U.S., 677 F.3d 519 (3d Cir. 2012) (de novo review of dismissal and pleading standards)
Haines v. Kerner, 404 U.S. 519 (1972) (liberal construction of pro se pleadings)
Murray v. Bledsoe, 650 F.3d 246 (3d Cir. 2011) (affirmance may be based on any record-supported ground)
McTernan v. City of York, 577 F.3d 521 (3d Cir. 2009) (pleading facts taken as true and construed favorably)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility pleading standard)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (Iqbal/Twombly framework)
Nicholas v. Pennsylvania State Univ., 227 F.3d 133 (3d Cir. 2000) (limits on due process interests in university contexts)
DeJournett v. Block, 799 F.2d 430 (8th Cir. 1986) (no constitutionally protected interest in future loans)
Dozier v. Loop Coll., 776 F.2d 752 (7th Cir. 1985) (no right to subsidized education)
Mammaro v. N.J. Div. of Child Prot. & Permanency, 814 F.3d 164 (3d Cir. 2016) (conscience-shocking standard)
Schmidt v. Creedon, 639 F.3d 587 (3d Cir. 2011) (procedural due process: notice and hearing)
Village of Willowbrook v. Olech, 528 U.S. 562 (2000) (equal protection requires intentional differential treatment)
Kost v. Kozakiewicz, 1 F.3d 176 (3d Cir. 1993) (appellate forfeiture for unstated claims)
Nathanson v. Medical Coll. of Pa., 926 F.2d 1368 (3d Cir. 1991) (causal nexus required for disability discrimination)
Grayson v. Mayview State Hosp., 293 F.3d 103 (3d Cir. 2002) (futility standard for leave to amend)