Amaya v. Brater
2013 Ind. App. LEXIS 39
| Ind. Ct. App. | 2013Background
- Amaya, an Indiana University School of Medicine student, was dismissed for alleged cheating on a mini-block exam.
- Amaya sued IUSM and related administrators, raising contract and good faith/fair dealing claims.
- The trial court granted summary judgment for IUSM on counts IV and V after briefing and a hearing.
- Amaya challenged the summary judgment, asserting breach of implied contract and related procedural failures.
- IUSM argued the relationship is an implied contract but that courts defer to educational judgments absent bad faith.
- The appellate court affirmed, holding no genuine issue of material fact and that IUSM substantially followed its procedures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Amaya’s breach-of-contract claim survives summary judgment | Amaya contends IUSM breached implied contract terms | IUSM argues no bad faith/arbitrary conduct and proper procedures were followed | No genuine issue; judgment for IUSM on contract claim |
| Whether a duty of good faith and fair dealing provides a separate claim | Amaya asserts a separate good faith claim | IUSM argues the duty does not apply as a separate claim in this context | Counts IV and V duplicative; no separate good faith claim valid |
Key Cases Cited
- Neel v. Indiana University Board of Trustees, 435 N.E.2d 607 (Ind.Ct.App. 1982) (implied contract between student and university; review for bad faith or arbitrariness)
- Gordon v. Purdue Univ., 862 N.E.2d 1244 (Ind.Ct.App. 2007) (good faith and professional judgment deference; non-arbitrary determinations)
- Gagne v. Trs. of Ind. Univ., 692 N.E.2d 489 (Ind.Ct.App. 1998) (limits on judicial intervention in academic determinations)
- Ross v. Creighton Univ., 957 F.2d 410 (7th Cir. 1992) (university contract-like obligations; academic process fairness)