Becker v. Washington State University
165 Wash. App. 235
| Wash. Ct. App. | 2011Background
- Becker, a PhD student in WSU’s experimental psychology program, was disenrolled for failing to maintain a 3.0 GPA and to complete prelims by deadlines.
- WSU’s Graduate School policies required prelims by the sixth semester and continuous enrollment with a 3.0 GPA; failure could result in termination.
- Becker alleged contract, promissory estoppel, age discrimination, retaliation, WLAD, §1983, negligent and defamation claims; the trial court granted summary judgment for WSU.
- Becker changed advisors multiple times; she was advised and offered a contract to structure study, which she refused.
- In spring 2005 Becker enrolled, then left campus and earned an ‘F’ in Psych 800, dropping her GPA below 3.0 and triggering disenrollment.
- On May 12, 2005, graduate school disenrolled Becker; she sued in 2007 and appeals followed, with the court affirming summary judgment for WSU.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Contract breach claim viability | Becker asserts WSU failed to provide clear academic guidelines. | WSU argues policy and extensions sufficiently defined expectations; disenrollment for academic progress was legitimate. | No contract breach; discretionary academic controls justified. |
| Negligent misrepresentation and promissory estoppel | Fournier’s assurances created a reliance inducing educational progress. | Promised actions were not made by an authorized official and were not definite or justifiable promises. | Promissory estoppel and negligent misrepresentation denied. |
| Retaliation under RCW 49.60 | Dismissal was retaliation for filing age discrimination complaints. | Termination based on legitimate, non-discriminatory academic progress failures. | Prima facie retaliation not established; no causal link shown. |
| Age discrimination under WLAD and ADA | Becker faced age-based discrimination affecting academic outcomes. | No protected employment relationship; dismissal was for academic reasons. | WLAD/ADA claims rejected; no permissible basis for age discrimination. |
| §1983 civil rights claim and qualified immunity | Actions were arbitrary and violated constitutional rights; immunity should be overcome. | Officials are shielded by qualified immunity absent due process or equal protection violations. | No constitutional rights violation; qualified immunity applied; §1983 claim properly dismissed. |
Key Cases Cited
- DePhillips v. Zolt Constr. Co., 136 Wn.2d 26 (Wash. 1998) (elements of contract; mutual intent and definiteness)
- Hoglund v. Meeks, 139 Wn. App. 854 (Wash. Ct. App. 2007) (contract formation and interpretation; objective manifestation)
- Keystone Land & Dev. Co. v. Xerox Corp., 152 Wn.2d 171 (Wash. 2004) (reasonableness standard for university-student expectations)
- Marquez v. Univ. of Wash., 32 Wn. App. 302 (Wash. Ct. App. 1982) (student-university relationship is contractual; publications and procedures guide expectations)
- Kilian v. Atkinson, 147 Wn.2d 16 (Wash. 2002) (age discrimination scope limited to employment under WLAD)
- McClarty v. Totem Elec., 157 Wn.2d 214 (Wash. 2006) (prima facie age-discrimination framework; pretext standard)
- Reeves v. Sanderson Prods., Inc., 530 U.S. 133 (U.S. 2000) (pretext and burden-shifting framework in discrimination cases)
- Hill v. BCTI Income Fund-I, 144 Wn.2d 172 (Wash. 2001) (parental analysis of non-discriminatory reasons and pretext)
- McCormick v. Lake Wash. Sch. Dist., 99 Wn. App. 107 (Wash. Ct. App. 1999) (promissory estoppel elements in education context)
- Havens v. C&D Plastics, Inc., 124 Wn.2d 158 (Wash. 1994) (promissory estoppel/general contract principles)
- Estevez v. Faculty Club of Univ. of Wash., 129 Wn. App. 774 (Wash. Ct. App. 2005) (retaliation prima facie framework under RCW 49.60)