570 F. App'x 66
2d Cir.2014Background
- Plaintiff James "Jak" Knelman, a former Middlebury College hockey player, was removed from the team midseason by coach Bill Beaney.
- Knelman sued Middlebury and Beaney in diversity court asserting breach of contract and breach of fiduciary duty, among other claims.
- The district court granted summary judgment for defendants on certain claims; remaining claims were later dismissed by stipulation.
- Knelman argued the College Handbook and the NCAA Manual created contractual due-process protections preventing unilateral coach discipline.
- He also argued that Middlebury and Beaney owed a fiduciary duty to him and breached it by failing to provide process.
- The Second Circuit affirmed the district court, rejecting both the contract and fiduciary-duty theories.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Handbook/NCAA Manual created enforceable contract rights requiring due process before coach discipline | Handbook and NCAA Manual include "due process" and fairness provisions that were incorporated into Knelman's contract with Middlebury | Handbook's disciplinary procedures apply to academic/non-academic judicial processes, not to coach personnel decisions; NCAA provisions were not specifically incorporated | Court held no contractual right: Handbook did not cover coach discipline and did not specifically incorporate NCAA fairness provisions |
| Whether college and coach owed a fiduciary duty to student-athlete | Knelman urged recognition of a fiduciary relationship requiring duties to provide process and act for student benefit | Defendants argued Vermont law does not recognize a special fiduciary relationship between college and students | Court refused to recognize a fiduciary duty under Vermont law and affirmed dismissal |
Key Cases Cited
- Reynolds v. Sterling Coll., 750 A.2d 1020 (Vt. 2000) (student–college relationship contractual; only specific handbook provisions enforceable)
- Fellheimer v. Middlebury Coll., 869 F. Supp. 238 (D. Vt. 1994) (courts cautious applying commercial contract principles to academic context)
- Newton v. Smith Motors, Inc., 175 A.2d 514 (Vt. 1961) (foreign writing incorporated only by specific reference or clear mutual understanding)
- Wood v. Strickland, 420 U.S. 308 (1975) (courts should not substitute their judgment for school administrators')
- Handverger v. City of Winooski, 38 A.3d 1158 (Vt. 2011) (definition of fiduciary relationship under Vermont law)