507 F.Supp.3d 406
N.D.N.Y.2020Background
- Three RPI undergraduates (Ford, Deecher, Habicht) sued after RPI moved to remote instruction in March 2020 and required students to vacate campus; plaintiffs assert they paid for an on‑campus experience described in RPI publications (including the "Plan 2024" and catalog) and were deprived of promised in‑person programs (e.g., CLASS and the Arch).
- Plaintiffs seek class relief across tuition, activity fees, housing, and meal plans, alleging breach of contract, unjust enrichment (alternative), conversion, GBL §§ 349/350 claims, and promissory estoppel; RPI moved for judgment on the pleadings under Fed. R. Civ. P. 12(c).
- Key factual points: RPI’s Plan/catalog repeatedly described mandatory, residential, time‑based programs (CLASS/Arch); RPI issued partial room/board refunds but deducted the net value of students’ financial aid; classes moved fully online effective March 16, 2020.
- Procedural posture: Amended consolidated complaint filed; RPI answered and moved for judgment on the pleadings; the court heard oral argument and issued the decision on December 16, 2020.
- Practical dispute framed: whether RPI’s publications contain specific, enforceable promises of an on‑campus experience and related services that, if unfulfilled, give rise to contract or quasi‑contract relief despite the COVID‑19 shutdown.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RPI’s publications (Plan/catalog) created a specific, enforceable promise of on‑campus programs supporting breach of contract for tuition | Plan/catalog expressly promised mandatory residential programs (CLASS/Arch); plaintiffs paid expecting that in‑person experience | Publications are aspirational/goals; at most a general tuition‑for‑instruction promise was made, and instruction continued online | Court: Publications (catalog and Plan) plausibly state specific promises; breach‑of‑contract tuition claim survives (12(c) denied) |
| Whether plaintiffs’ tuition claim is barred as educational malpractice (challenging quality of instruction) | Claim targets loss of on‑campus components and services, not academic decision‑making or instructional quality | If tuition is payment for instruction, plaintiffs’ claim seeks improper judicial review of academic judgments or impermissible educational malpractice | Court: Claim is not disguised educational malpractice; plaintiffs challenge lost on‑campus benefits, so tuition recovery may be available |
| Whether activity/fee and housing/meal refund claims are actionable | Activity fee confers specific Rensselaer Union privileges; plaintiffs lacked access after shutdown; room/board promised and partial refunds reduced by financial aid are unfair | RPI provided instruction and partial refunds; withheld amounts reflect financial aid adjustments and continuing services | Court: Activity‑fee and housing/meal claims plausibly allege specific promises and unfair refund practice; these claims survive (12(c) denied) |
| Whether unjust enrichment claims are duplicative and must be dismissed | Alternative pleading; if contract does not cover relief (or is impossible), unjust enrichment remains available | Existence of an implied contract forecloses quasi‑contract recovery | Court: Unjust enrichment pled in the alternative survives at this stage because contract coverage is disputed |
| Whether conversion claim (money paid) is viable | Tuition/fees constituted a specific fund that RPI converted | Money was not a segregated, identifiable fund after payment; conversion cannot enforce ordinary payment obligations | Court: Conversion claim dismissed (12(c) granted) |
| Whether GBL §§ 349/350 claims for deceptive practices are viable | Advertising of on‑campus learning was misleading when RPI could not provide it | No objectively deceptive practice; no reasonable consumer would expect in‑person instruction to continue through a pandemic/state shutdown | Court: GBL §§ 349/350 claims dismissed (12(c) granted) |
| Whether promissory estoppel is available | Plaintiffs reasonably relied on clear promises in RPI publications to their detriment | Publications are aspirational; any enforceable promises are contractual, barring promissory estoppel | Court: Promissory estoppel survives as an alternative theory at this stage (12(c) denied) |
Key Cases Cited
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard requires plausibility)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard and plausibility analysis)
- Papelino v. Albany College of Pharmacy, 633 F.3d 81 (2d Cir. 2011) (student‑university implied contract and duty of good faith)
- Maas v. Cornell University, 721 N.E.2d 966 (N.Y. 1999) (courts’ limited role in university administrative matters)
- Manufacturers Hanover Trust Co. v. Chemical Bank, 559 N.Y.S.2d 704 (N.Y. App. Div. 1990) (conversion requires a specific, identifiable fund)
- Thyroff v. Nationwide Mutual Insurance Co., 460 F.3d 400 (2d Cir. 2006) (definition and elements of conversion under New York law)
- Boule v. Hutton, 328 F.3d 84 (2d Cir. 2003) (objective test for materially misleading acts under consumer protection law)
- Keefe v. New York Law School, 897 N.Y.S.2d 94 (N.Y. App. Div. 2010) (enforceable promises to students arise from specific bulletins/catalogs, not general policies)