Gilani v. University of Texas Southwestern Medical Center
3:21-cv-01461
| N.D. Tex. | Mar 13, 2023Background
- Al Gilani, a medical student at UT Southwestern, was placed on academic probation after failing a global health summer research elective and later failed the gastrointestinal systems (GI) course; he was dismissed twice after failing the GI course and its remediation.
- Gilani successfully appealed his first dismissal but not his second; he alleges deviations from normal academic procedures (e.g., exclusion from a curve, hand-grading, withholding preliminary scores) and cites statements and comparator students suggesting racial bias.
- In 2021 Gilani sued UT Southwestern and four individual administrators, asserting §1983 claims for procedural and substantive due process violations and a Title VI claim for intentional discrimination; the case was removed to federal court.
- Defendants moved to dismiss, asserting Eleventh Amendment/sovereign immunity, qualified immunity, and that Gilani failed to plead plausible due process or Title VI claims.
- The court held that Ex parte Young allows prospective injunctive relief to correct and release transcripts (but not to remove a tuition charge), dismissed both procedural and substantive due process claims with prejudice, and allowed Gilani’s Title VI claim to proceed; individual defendants are entitled to qualified immunity on the §1983 claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of Ex parte Young to transcript relief | Gilani seeks prospective injunctions to correct and release transcripts to pursue re-enrollment/transfers | Defendants say relief is retroactive and barred by Eleventh Amendment | Court: Ex parte Young permits transcript correction and release (ongoing injury); removing tuition charge is barred |
| Qualified immunity waiver | Gilani argues removal and procedural posture waived immunity | Defendants argue qualified immunity preserved and properly raised | Court: Defendants did not waive; qualified immunity available; merits must be assessed first |
| Procedural due process (§1983) | Gilani contends dismissal was disciplinary and lacked adequate process | Defendants say dismissals were academic and provided notice/appeals | Court: Dismissal was academic; notice and appeals were provided; procedural due process claim dismissed |
| Substantive due process (§1983) | Gilani alleges arbitrary/capricious conduct (curve exclusion, hand-grading) amounting to denial of education | Defendants argue academic decisions are entitled to deference and not beyond pale | Court: Allegations insufficient to overcome deference to academic judgment; substantive claim dismissed |
| Title VI intentional discrimination | Gilani alleges discriminatory intent via departures from norms, comparator treatment, and faculty statements | Defendants assert insufficient facts to plausibly plead intent | Court: Allegations of procedural departures, comparators, and statements plausibly plead intentional discrimination; Title VI claim survives dismissal |
Key Cases Cited
- Ex parte Young, 209 U.S. 123 (establishes narrow exception to Eleventh Amendment for prospective injunctive relief)
- Alden v. Maine, 527 U.S. 706 (discusses state sovereign immunity)
- Seminole Tribe of Fla. v. Florida, 517 U.S. 44 (limits Ex parte Young to ongoing federal-law violations)
- Va. Office for Prot. & Advoc. v. Stewart, 563 U.S. 247 (clarifies inquiry for Ex parte Young relief)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards and reasonable inference rule)
- Harlow v. Fitzgerald, 457 U.S. 800 (qualified immunity standard)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity framework flexibility)
- Mathews v. Eldridge, 424 U.S. 319 (due process balancing test)
- Goss v. Lopez, 419 U.S. 565 (due process protections for disciplinary suspensions)
- Bd. of Curators v. Horowitz, 435 U.S. 78 (deference to academic judgments in dismissals)
- Regents of Univ. of Mich. v. Ewing, 474 U.S. 214 (limits judicial review of academic decisions)
- Saucier v. Katz, 533 U.S. 194 (sequencing of qualified-immunity analysis)