959 F. Supp. 2d 951
E.D. La.2013Background
- Plaintiff Anna Mathai was a medical student at LSUHSC who was dismissed from the School of Medicine in 2012.
- Mathai signed and was bound by two Fitness for Duty/Drug Testing Continuation of Enrollment Contracts—Aug. 25, 2011 and Feb. 15, 2012—that conditioned continued enrollment on CAP-recommended treatment and compliance.
- CAP referred Mathai for a Palmetto Addiction Recovery Center evaluation, which diagnosed polysubstance dependence and narcissistic traits despite negative drug screens.
- Mathai refused a three-month inpatient treatment program recommended by Palmetto as incompatible with her studies, and she was subsequently dismissed by Dr. Steve Nelson on April 5, 2012.
- Mathai filed suit under 42 U.S.C. § 1983 against LSU Board of Supervisors and Dr. Nelson alleging procedural due process and breach of contract; the court granted dismissal for lack of jurisdiction and qualified immunity.
- The court held Mathai’s dismissal was academic, not disciplinary, and therefore only minimal notice was required; it dismissed the § 1983 claims against the Board and Nelson and the breach of contract claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether LSU Board of Supervisors is subject to § 1983 liability. | Mathai argues Board is a proper defendant despite sovereign immunity. | Board is an arm of the state and immune from § 1983 claims. | Claims against the Board were dismissed for Eleventh Amendment immunity. |
| Whether § 1983 claims against Dr. Nelson in official capacity are barred by Eleventh Amendment. | Asks for prospective relief via reinstatement. | Official-capacity claims are suits against the state, barred, except for prospective relief under Ex parte Young. | Allowed injunctive relief claims under Ex parte Young; however, plaintiff’s due process claims were not stated. |
| Whether § 1983 claims against Dr. Nelson in his individual capacity survive. | Plaintiff asserts constitutional violations by Nelson. | Nelson is entitled to qualified immunity. | Claims against Nelson in his individual capacity were dismissed on qualified immunity. |
| Whether the breach of contract claim against defendants is actionable in federal court. | Plaintiff seeks contract-based remedies under school policies. | State-law contract claim barred by sovereign immunity. | The breach-of-contract claim was dismissed for lack of federal jurisdiction. |
Key Cases Cited
- Goss v. Lopez, 419 U.S. 565 (U.S. 1975) (due process rights for students in disciplinary actions; not all academic dismissals require hearings)
- Horowitz v. Board of Curators of Univ. of Mo., 435 U.S. 78 (U.S. 1978) (academic vs disciplinary dismissal; no due process required for academic dismissals)
- Shaboon v. Duncan, 252 F.3d 722 (5th Cir. 2001) (academic vs disciplinary dismissal in medical training; substantial internal factors considered for fitness to practice)
- Will v. Michigan Dept. of State Police, 491 U.S. 58 (U.S. 1989) (official-capacity suits and Eleventh Amendment immunity; Ex parte Young exception for prospective relief)
- Ex parte Young, 209 U.S. 123 (U.S. 1908) (exemption to Eleventh Amendment for ongoing unconstitutional violations actionable via injunction)