Charleston v. Board of Trustees of the University of Illinois
2013 U.S. App. LEXIS 25451
| 7th Cir. | 2013Background
- Gerald Charleston, a 4th-year medical student at University of Illinois College of Medicine, faced complaints from two preceptors alleging plagiarism, late quizzes, missing signatures, lack of a preceptor for part of the rotation, and poor performance.
- The Student Progress Committee reviewed the preceptors’ complaint (Charleston was not allowed to attend but submitted a letter) and recommended mentoring rather than dismissal.
- Without Charleston’s notice or opportunity to address it, the complaint and a new allegation from Associate Dean James Hall (that Charleston had acted unprofessionally in 2008) were forwarded to the Executive Committee, which decided to dismiss Charleston; subsequent appeals within the college were unsuccessful and the dismissal was finalized.
- Charleston sued under 42 U.S.C. § 1983 alleging violations of procedural and substantive due process and the Equal Protection Clause (class-of-one), plus state-law claims; district court dismissed federal claims under Rule 12(b)(6) and declined supplemental jurisdiction over state claims.
- On appeal, the Seventh Circuit assumed complaint facts true but affirmed dismissal, concluding Charleston failed to plead a protected property interest, a fundamental right, or plausible class-of-one discrimination, and that amendment would be futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Procedural due process — property interest in education | Charleston: has a protected property interest in continued medical education (implied contract or school policies/statutes guaranteed process) | Defendants: no stand-alone property right in university education; plaintiff failed to plead specific source of an implied contract or specific statutory promise | Court: Dismissed — no protected property interest pleaded; procedural due process claim fails |
| Substantive due process — deprivation of fundamental right or irrational state action | Charleston: dismissal violated substantive due process; he has right to public higher education benefits | Defendants: no fundamental right to education or graduate education; absent property interest, substantive claim fails; action rationally related to legitimate interest | Court: Dismissed — no fundamental right pleaded and no protected interest to base substantive claim on |
| Equal protection — class-of-one claim (singled out) | Charleston: was singled out, subjected to harsher treatment than similarly situated students; actions stemmed from animus and lacked rational basis | Defendants: plaintiff failed to identify similarly situated individuals or show irrationality/intentional discrimination; different alleged misconduct supports differing treatment | Court: Dismissed — pleadings lacked facts about comparable students and did not plausibly show irrational or intentionally discriminatory treatment |
| Denial of leave to amend | Charleston: district court should have allowed amendment to cure pleading defects | Defendants: amendment would be futile; plaintiff gave no specifics on how to cure defects | Held: Affirmed — district court did not abuse discretion where plaintiff offered no meaningful proposed amendments and proposed additions would not cure legal deficiencies |
Key Cases Cited
- Brooks v. Ross, 578 F.3d 574 (7th Cir. 2009) (complaint must plead factual content making liability plausible)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleadings)
- Bissessur v. Ind. Univ. Bd. of Trs., 581 F.3d 599 (7th Cir. 2009) (no stand-alone property interest in education; implied-contract inquiry)
- Williams v. Wendler, 530 F.3d 584 (7th Cir. 2008) (students do not automatically have constitutional property interest in continued education)
- Olim v. Wakinekona, 461 U.S. 238 (1983) (state-created procedural entitlements do not create substantive federal rights beyond process provided)
- Goss v. Lopez, 419 U.S. 565 (1975) (public education entitlement where statute creates right; distinguishes when statutory guarantee exists)
- Park v. Indiana Univ. Sch. of Dentistry, 692 F.3d 828 (7th Cir. 2012) (requiring adequate pleading of comparators and distinguishing differing misconduct)
- Del Marcelle v. Brown Cnty. Corp., 680 F.3d 887 (7th Cir. en banc 2012) (discusses standards for class-of-one claims in this circuit)
- Vill. of Willowbrook v. Olech, 528 U.S. 562 (2000) (class-of-one equal protection theory)
- San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (1973) (no fundamental right to education)