Gati v. University of Pittsburgh of the Commonwealth System of Higher Education, 91 A.3d 723

Appellee Y. Gati, a fifth-year student at the University of Pittsburgh School of Dental Medicine (SDM), was dismissed for dishonesty related to Wright’s consent form, after prior disciplinary warnings.
Gati was confronted by SDM officials; he admitted signing Wright’s name with Wright’s permission but lied about the details in the ensuing meeting.
SDM ultimately dismissed Gati; Dean Braun upheld the dismissal; Gati appealed to the trial court seeking equity relief and a preliminary injunction.
The trial court granted a May 23, 2013 injunction prohibiting SDM from dismissing Gati and ordering on-time graduation by June 30, 2013 subject to completion of procedures.
SDM sought emergency relief from the injunction; the trial court denied it on June 27, 2013; Gati graduated June 30, 2013.
On appeal, SDM challenges the injunction as improper interference with private disciplinary processes and argues contract/due process issues; the court vacates the May 23 and June 27 orders and remands for merits litigation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the injunction was proper relief	Gati contends the court had grounds to grant relief to prevent irreparable harm.	SDM argues the university’s internal disciplinary process should not be overridden by equity.	Inapplicable; injunction vacated; no clear right to relief.
Whether SDM violated contract and/or due process	Gati asserts the handbook created a contract and due process protections were breached.	SDM argues it followed its written procedures and policies for dismissal; no contractual breach shown.	No clear right to relief; SDM's procedures complied with handbook; no due process violation proven.
Whether the court improperly interfered with academic/disciplinary decisions	Gati claims the court’s injunction overridden SDM’s disciplinary judgment.	SDM asserts the court cannot micromanage academic decisions and should be deferential.	The trial court improperly interfered with SDM’s disciplinary authority; injunction vacated.
Whether state-related status affects analysis	Gati argues state-related status may implicate due process/contract notions.	SDM contends status is irrelevant to outcome here.	The state-related status does not alter the outcome; the SDM’s obligations are nonetheless governed by contract and due process principles.

Goss v. Lopez, 419 U.S. 565 (1975) (due process in public school disciplinary matters; liberty/property interests)
Regents of Univ. of Mich. v. Ewing, 474 U.S. 214 (1985) (assumed protected property right in higher education; due process considerations for public institutions)
Board of Curators of Univ. of Mo. v. Horowitz, 435 U.S. 78 (1978) (due process in higher education student disciplinary proceedings; limitations on review)
Boehm v. Univ. of Pa. Sch. of Vet. Med., 573 A.2d 577 (Pa. Super. 1990) (private university disciplinary procedures; substantial compliance and fairness requirement)
Reardon v. Allegheny Coll., 926 A.2d 477 (Pa. Super. 2007) (contractual analysis of handbooks; plaintiff afforded rights promised in handbook)
Swartley v. Hoffner, 734 A.2d 915 (Pa. Super. 1999) (contractual nature of private college-student relationship; written policies govern)
Schulman v. Franklin & Marshall Coll., 538 A.2d 49 (Pa. Super. 1988) (reluctance to interfere in college proceedings; deference to academic judgment)
Overland Enter., Inc. v. Gladstone Partners, LP, 950 A.2d 1015 (Pa. Super. 2008) (distinction between mandatory and prohibitory injunctions; need for clear right to relief)
Summit Towne Ctr. v. Shoe Show of Rocky Mount, Inc., 573 Pa. 637 (2003) (six-factor test for preliminary injunctions; need for all factors to be satisfied)