528 F.Supp.3d 15
D. Conn.2021Background
- Quinnipiac University shifted in-person Spring 2020 instruction online in March 2020 due to COVID-19; students (and parents who paid on their behalf) allege they paid for in-person instruction and received inferior online services.
- Plaintiffs (two student plaintiffs and two parent plaintiffs) sued for breach of contract, breach of implied contract, unjust enrichment, and conversion; they sought class certification.
- Quinnipiac moved to dismiss; the Court solicited supplemental briefing on whether the parent plaintiffs have Article III standing.
- Quinnipiac offered housing/dining credits but no tuition refunds; Plaintiffs rely on the university Bulletin and promotional materials to allege a specific promise of on-campus instruction.
- The Court denied dismissal of the students’ breach and unjust enrichment claims (permitting factual development), but dismissed the parent plaintiffs for lack of standing and granted dismissal of the conversion claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Parent Plaintiffs’ Article III standing | Parents suffered concrete economic injury because they paid tuition and were deprived of value | Parents lack standing: no contract between parents and university; not intended third-party beneficiaries; injury belongs to students | Parents lack Article III standing; parent plaintiffs dismissed |
| Educational-malpractice doctrine bar | Claims are commercial (contract) disputes about promised services, not academic quality | Claims impermissibly require court to assess quality/value of education (educational malpractice) | Doctrine inapplicable at pleading stage because plaintiffs allege a specific promise of in-person instruction; may be reconsidered if resolution requires academic-value determinations |
| Existence of a specific contractual promise to provide in-person instruction | Bulletin, course listings, differential pricing for online v. on-campus programs, and registration conduct plausibly create (express or implied) promise | Bulletin language is aspirational/vague and reserved change rights; no precise contractual term guaranteeing in-person delivery | Plaintiffs plausibly alleged a specific promise at the pleading stage; breach claims survive to discovery |
| Unjust enrichment and conversion claims | Unjust enrichment pleaded in the alternative; university retained non-gratuitous benefits by providing online instead of in-person services; conversion alleges wrongful retention of tuition | Unjust enrichment improper if contract governs; conversion inappropriate because funds were not specific/identifiable and claim sounds in contract | Unjust enrichment allowed (pled in alternative); conversion dismissed because claim sounds in contract and funds not specifically traceable |
Key Cases Cited
- Mahon v. Ticor Title Ins. Co., 683 F.3d 59 (2d Cir. 2012) (standing limits and case-or-controversy doctrine)
- Susan B. Anthony List v. Driehaus, 573 U.S. 149 (2014) (standing principles)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Article III standing elements)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard applied to factual allegations)
- Gupta v. New Britain Gen. Hosp., 239 Conn. 574 (1996) (educational malpractice doctrine and its contractual exceptions)
- Vertex, Inc. v. City of Waterbury, 278 Conn. 557 (2006) (implied-in-fact and implied-in-law contract doctrines)
- Mystic Color Lab, Inc. v. Auctions Worldwide, LLC, 284 Conn. 408 (2007) (conversion, debtor-creditor v. bailor-bailee distinction)
- SM Kids, LLC v. Google LLC, 963 F.3d 206 (2d Cir. 2020) (distinguishing contractual entitlement from Article III injury)