Amir Al-Dabagh v. Case Western Reserve Univ.
777 F.3d 355
| 6th Cir. | 2015Background
- District court ordered Case Western Reserve University School of Medicine to grant Amir Al-Dabagh a medical degree despite the university’s professionalism finding.
- Case Western appealed, arguing the decision was an improper substitution of academic judgment for law.
- University curriculum identifies nine core competencies with professionalism ranked first among them.
- Al-Dabagh had documented professionalism issues (lateness, a 2013 Hippo Ball incident, internship performance problems, and a driving-while-intoxicated conviction).
- Committee on Students repeatedly reviewed exams, clinical performance, and professional behavior; its decision not to award the degree was ultimately relied on to dismiss him.
- The court held that professionalism is an academic judgment deserving deference, reversing the district court’s diploma order.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether professionalism determinations are academic judgments subject to deference | Al-Dabagh; case should review for error, not academic policy. | Case Western; professionalism is an academic criterion within curriculum. | Yes; upheld as academic judgment, not to be overridden. |
| Whether the district court could compel a degree despite university's decision | Al-Dabagh seeks diploma despite Committee denial. | University's decision on professionalism controls graduation. | District court erred; reversal of the order. |
| Whether the student handbook contracts permit court review of academic decisions | handbook allows review of non-academic disciplinary actions. | Professionalism is part of the academic curriculum, not outside review. | Academic judgment shielded from customary deference. |
Key Cases Cited
- Horowitz v. Bd. of Curators of Univ. of Mo., 435 U.S. 78 (1978) (academic-dismissal for hygiene concerns recognized as academic.)
- Regents of Univ. of Mich. v. Ewing, 474 U.S. 214 (1985) (courts defer to academic judgments absent substantial departure.)
- Bleicher v. Univ. of Cincinnati Coll. of Med., 604 N.E.2d 783 (1992) (overturns require arbitrary and capricious conduct in academic decisions.)
- Doherty v. S. Coll. of Optometry, 862 F.2d 570 (1988) (judicial reluctance to second-guess curricular decisions.)
- Ku v. Tennessee, 322 F.3d 431 (2003) (academic evaluations may extend beyond raw grades.)