Linda Martinson v. Regents of the University of Mich.
562 F. App'x 365
6th Cir.2014Background
- Martinson was expelled from the University of Michigan School of Nursing after a CAASS proceeding found code-of-conduct violations.
- The district court dismissed most state-law claims and granted summary judgment against Martinson on procedural due process, while leaving substantive due process claims to be resolved.
- Martinson alleged procedural and substantive due process violations under 42 U.S.C. § 1983 against the School and Administrators.
- Administrators notified Martinson of alleged conduct problems and scheduled a series of hearings, ultimately expelling her after CAASS independent review.
- Martinson did not attend key hearings and did not timely respond to information packets, which the district court treated as a lack of due process safeguards.
- The court affirmed dismissal of both procedural and substantive due process claims on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Martinson received due process in the university disciplinary process. | Martinson contends lack of notice and opportunity to be heard violated due process. | Defendants argue notices and hearings provided constitutionally adequate process. | Procedural due process claim affirmed; sufficient notice and opportunity to be heard existed. |
| Whether Martinson's substantive due process claim is plausible. | Martinson argues government action was arbitrary and capricious. | Expulsion based on observed misconduct, not arbitrary or capricious action. | Substantive due process claim rejected; not plausible. |
Key Cases Cited
- Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (U.S. 1950) (notice must be reasonably calculated under all circumstances)
- Flaim v. Medical College of Ohio, 418 F.3d 629 (6th Cir. 2005) (Mathews v. Eldridge framework for due process varies by context)
- Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (balancing test for notice and hearing requirements)
- Rogers v. Tenn. Bd. of Regents, 273 F. App’x 458 (6th Cir. 2008) (public education interests; due process not automatically protected by substantive guarantees in higher ed)
- Estate of Barney v. PNC Bank, 714 F.3d 920 (6th Cir. 2013) (pleading standard at summary judgment under Iqbal)
- Alexander v. CareSource, 576 F.3d 551 (6th Cir. 2009) (summary judgment burden on non-movant without responsive evidence)
- Bell v. Ohio State University, 351 F.3d 240 (6th Cir. 2003) (substantive due process in professional-education context)