MOORE v. GEORGETOWN UNIVERSITY
1:25-cv-01415
| D.D.C. | Jul 21, 2025Background
- Plaintiff Christopher Moree, a Bahamian citizen, was dismissed from Georgetown University School of Medicine (GUSOM) after failing to meet academic requirements over two years, including multiple failed and "unsatisfactory progress" marks.
- After dismissal, Moree unsuccessfully appealed through school procedures, including to the Committee on Student Appeals and the Dean.
- Moree then filed suit pro se, alleging breach of contract, bad faith, ADA and Rehabilitation Act violations, D.C. Human Rights Act violations, and intentional infliction of emotional distress (IIED), seeking a temporary restraining order (TRO) or preliminary injunction for readmission.
- The Court treated the TRO as a motion for preliminary injunction, setting briefing after finding no urgency since plaintiff could litigate from the Bahamas.
- Moree argued that dismissal was due to arbitrary grading and discriminatory failure to accommodate his newly diagnosed ADHD; he further cited reputational, educational, and immigration harms if not readmitted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Enforceability of Handbook/Policies | Handbook and Non-Discrimination Notice are contracts entitling him to due process and disability rights | Policies & handbook are not enforceable contracts; explicitly disclaim contractual force | Not enforceable as contracts |
| Academic Dismissal as Arbitrary/Capricious | Faculty acted arbitrarily, especially over minor grading; dismissal unfair | Faculty applied standards properly and with discretion; Moree failed to meet requirements | Court will not second-guess academic judgments |
| Disability Discrimination (ADA/Rehab) | GUSOM failed to accommodate newly diagnosed ADHD | Plaintiff failed to inform the school of disability or seek accommodation before dismissal | No violation—school not on notice |
| Irreparable Harm/Preliminary Relief | Dismissal causes career, reputational, and immigration harms justifying injunction | Harms are compensable or speculative; no irreparable injury shown | No irreparable harm; injunction denied |
Key Cases Cited
- Winter v. Nat. Res. Def. Council, Inc., 555 U.S. 7 (articulates four-factor test for preliminary injunction)
- Regents of Univ. of Mich. v. Ewing, 474 U.S. 214 (judicial deference to academic decisions)
- Bd. of Curators of Univ. of Mo. v. Horowitz, 435 U.S. 78 (courts should avoid second-guessing academic judgment)
- Basch v. George Washington Univ., 370 A.2d 1364 (student handbooks may not create binding contracts)
- Minch v. District of Columbia, 952 A.2d 929 (elements for IIED under D.C. law)
- Eastbanc, Inc. v. Georgetown Park Assocs. II, L.P., 940 A.2d 996 (no contract where no reciprocal obligation)
- Allworth v. Howard Univ., 890 A.2d 194 (limited judicial review of academic contract disputes)