Choi v. University of Texas Health Science Center
633 F. App'x 214
5th Cir.2015Background
- Jin Choi, a dental student at UT Health Science Center at San Antonio, struggled academically from the start and repeated first-year classes.
- During second year he was diagnosed with ADD but did not disclose the diagnosis to the School until the dismissal process after failing a third‑year clinical course.
- Choi was placed in remediation during third year and ultimately failed a clinical course, prompting dismissal; he appealed to the School dean and the University and lost.
- Choi sued under the ADA and Section 504 of the Rehabilitation Act, claiming the School failed to provide reasonable accommodations for his ADD.
- The district court dismissed his ADA and Rehabilitation Act failure‑to‑accommodate claims under Rule 12(b)(6); the Fifth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Choi alleged the School knew of his disability‑related limitations such that it had a duty to accommodate | Choi argued his limitations were open, obvious, or otherwise known (faculty comments, observed inattention, faculty asked about a learning disability) | School argued it lacked knowledge of any limitations needing accommodation because Choi only disclosed a diagnosis late and never described resulting limitations | Court held Choi failed to plead that the School knew of his disability‑related limitations; dismissal affirmed |
| Whether Choi pleaded a plausible failure‑to‑accommodate claim under Iqbal/Twombly pleading standards | Choi contended his factual allegations suffice to make the claim plausible | Defendants argued the complaint offered only labels and conclusions and lacked factual enhancement tying limitations to the School's knowledge | Court applied Iqbal/Twombly standards and found allegations insufficient, affirming dismissal |
Key Cases Cited
- Elsensohn v. St. Tammany Par. Sheriff's Office, 530 F.3d 368 (5th Cir.) (standard of review for Rule 12(b)(6))
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must state a plausible claim; labels/conclusions insufficient)
- Neely v. PSEG Tex., Ltd. P’ship, 735 F.3d 242 (5th Cir.) (elements of failure‑to‑accommodate claim)
- Bennett‑Nelson v. La. Bd. of Regents, 431 F.3d 448 (5th Cir.) (public entities’ obligation to make reasonable accommodations)
- Taylor v. Principal Fin. Grp., Inc., 93 F.3d 155 (5th Cir.) (employer must know of specific limitations, not merely a disability)
- Gammage v. W. Jasper Sch. Bd. of Educ., 179 F.3d 952 (5th Cir.) (plaintiff must assert limitations resulting from disability)