111 F. Supp. 3d 978
E.D. Mo.2015Background
- Plaintiff attended Principia College (2009–2013), a Principia Corporation institution, and earned a Trustee-level scholarship.
- Plaintiff joined Principia’s Christian Science environment and was told the college would provide a healing, regulative community with specific behavioral and spiritual expectations.
- Plaintiff signed the Principia Pledge and the Principia Community Commitment, reinforcing obligations grounded in Christian Science beliefs.
- Plaintiff alleges that after reporting a possible terminal illness and a hostile music-class exclusion, Principia failed to act to protect her welfare.
- Plaintiff alleges severe stress-related symptoms and expenses, including insomnia and medical treatment, arising from Principia’s actions or inaction.
- Plaintiff filed a Second Amended Complaint asserting breach of contract, intentional infliction of emotional distress (IIED), negligent infliction of emotional distress (NIED), and negligence; the court granted the motion to dismiss without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the contract claim is cognizable against a university. | Lucero/educational promises were enforceable. | Educational malpractice claims are not cognizable in Missouri. | Breach of contract claims dismissed. |
| Whether IIED claim is sufficiently extreme and outrageous. | Instructors’ hostile treatment violated decency. | Conduct not extreme/outrageous enough; not solely intended to cause distress. | IIED claim dismissed. |
| Whether negligence/NIED claims establish duty and foreseeability. | School had duty to obtain medical care and prevent distress. | Adult student, vague illness; no duty proven; no substantial distress. | Negligence and NIED claims dismissed. |
Key Cases Cited
- Intertel, Inc. v. Sedgwick Claims Mgmt. Servs., 204 S.W.3d 183 (Mo.Ct.App.2006) (elements of contract claim; Missouri law on form of contract and damages)
- Lucero v. Curators of the Univ. of Mo., 400 S.W.3d 1 (Mo.Ct.App.2013) (educational promises aspirational, not contractual)
- Ross v. Creighton Univ., 957 F.2d 410 (7th Cir.1992) (educational malpractice concerns and limits on liability)
- Gibson v. Brewer, 952 S.W.2d 239 (Mo. banc 1997) (standard for extreme/outrageous conduct in IIED)
- K.G. v. R.T.R., 918 S.W.2d 795 (Mo. banc 1996) (IIED traditional-tort requirement regarding sole intent to distress)
- Stineman v. Fontbonne College, 664 F.2d 1082 (8th Cir.1981) (duty regarding medical assistance case; distinguishable facts)