Professional Massage Training Center, Inc. v. Accreditation Alliance of Career Schools & Colleges
781 F.3d 161
| 4th Cir. | 2015Background
- PMTC sued ACCSC for due process violations after accreditation denial in 2010; district court awarded damages and reinstatement.
- ACCSC is a private accrediting agency recognized to grant Title IV funding eligibility and oversee accreditation standards.
- PMTC underwent ACCSC’s multi-step accreditation process, including on-site visits, probation orders, and multiple written responses.
- The Commission ultimately denied renewal in 2012 due to continued failures in management continuity, learning resources, and faculty verification.
- PMTC appealed; the district court’s de novo-style review was challenged as improper; issues included bias and evidentiary scope.
- Court held the district court erred in de novo review; standard of review is substantial evidence/arbitrary and capricious; reversed on due process claim and remanded with directions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| What standard governs review of accrediting decisions? | PMTC argues for less deference, more de novo review by courts. | ACCSC argues for substantial evidence/arbitrary-and-capricious review with deference to expertise. | Deferential substantial-evidence standard governs review. |
| Did ACCSC violate PMTC's due process in its accreditation decision? | Bias and improper consideration tainted process; decision biased against Mee/PMTC. | No substantial bias; agency followed fair procedures and relied on substantial evidence. | No reversible due process violation; decision supported by substantial evidence. |
| Was the denial of accreditation supported by substantial evidence? | PMTC contends standards were vague and misapplied; PMTC lacked fair notice. | Evidence showed persistent failures in management, resources, and credential verification. | Denial supported by substantial evidence; not arbitrary or capricious. |
| Should PMTC's state-law claims be entertained? | State-law claims could provide additional remedies apart from HEA framework. | HEA exclusive-jurisdiction concerns preemption; but at minimum claims fail on merits. | State-law claims properly dismissed; no recoverable relief. |
Key Cases Cited
- McCulloch v. PNC Bank Inc., 298 F.3d 1217 (11th Cir. 2002) (HEA private right deference; no express private right of action)
- Cooley v. American Bar Ass’n, 459 F.3d 705 (6th Cir. 2006) (federal common law in accreditation review; deference framework)
- Wilfred Acad. of Hair & Beauty Culture v. S. Ass’n of Colls. & Schs., 957 F.2d 210 (5th Cir. 1992) (administrative deference to accrediting bodies; no de novo review)
- Med. Inst. of Minn. v. Nat'l Ass’n of Trade & Tech Schs., 817 F.2d 1314 (8th Cir. 1987) (fair procedures; substantial evidence standard)
- Chicago Sch. of Automatic Transmissions, Inc. v. Accreditation Alliance of Career Schs. & Colls., 44 F.3d 447 (7th Cir. 1994) (limits on de novo review; role of expertise)
- Nazeri v. Mo. Valley Coll., 860 S.W.2d 303 (Mo. 1993) (lack of justification in tort claims; improper interference concepts)
- Tex. Indus., Inc. v. Radcliff Materials, Inc., 451 U.S. 630 (Supreme Court 1981) (federal common law/jurisdiction considerations)