Cyrena Chang Paulin v. George Washington University School of Medicine and Health Sciences
878 F. Supp. 2d 241
D.D.C.2012Background
- Paulin, former PA student at GWU School of Medicine, completed nearly all requirements by Aug 2010 except final preceptorship and final exam, with a 3.27 GPA.
- Paulin was assigned to an Internal Medicine preceptorship, then removed for alleged lack of foundational knowledge and interpersonal issues; she was ultimately dismissed from the PA program.
- She was criticized by preceptors without patient-contact evidence and faced a nine-month appeals process culminating in dismissal on Apr 28, 2011.
- The IGS report contained factual errors about Paulin’s academic record, and the process allegedly lacked proper representation and consideration of notes.
- Paulin alleges contractual breaches (grading policy, treatment of her preceptorship, and disparate standards) and breach of the implied covenant of good faith and fair dealing.
- The court denied the University’s Rule 12(b)(6) motion, finding plausible contractual and implied-duty claims at this stage.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether GWU breached the contract with Paulin | Paulin alleges defects in preceptorship, grading, and review of notes; argues arbitrary treatment | University conformed to Bulletin policies; decisions were within contractual discretion | Denied; plausible contract claim survived at pleadings stage |
| Whether dismissal was arbitrary and capricious and merits deference | Facts show irrational basis or bad faith; not supported by rational performance | Academic decisions receive deference; need strong evidence of irrationality | Denied; court finds plausible facts suggesting potential arbitrary/dismissive basis |
| Whether GWU breached the implied covenant of good faith and fair dealing | University acted to deny the fruits of the contract through bad faith | No evidentiary showing of bad faith at this stage; performance within contract terms | Denied; material facts alleged may reveal bad faith or improper interference |
| Whether the plaintiff can state a claim for damages and injunctive relief | Breach and bad faith harmed her ability to complete the program | Relief dependent on contract and fact-finding; limited at motion to dismiss | Denied; claims survive to discovery and scheduling |
Key Cases Cited
- Alden v. Georgetown Univ., 734 A.2d 1103 (D.C. 1999) (judicial deference to academic decisions; contract rights may be vindicated in some circumstances)
- Allworth v. Howard Univ., 890 A.2d 194 (D.C. 2006) (contractual rights in academic dismissal; need rational basis or lack of good faith to prevail)
- Mesumbe v. Howard Univ., 706 F. Supp. 2d 86 (D.D.C. 2010) (elements of breach of contract; review limited but can be overcome by facts showing breach)