Zinter v. University of Minnesota
799 N.W.2d 243
Minn. Ct. App.2011Background
- Zinter, a former MLS student at the University of Minnesota, sought tuition refunds in conciliation court for three semesters and did not complete the MLS program.
- By Spring 2003 she had not completed the final project seminar; September 2003 she was told to take additional courses before registering for the seminar; Spring 2004 architecture course was completed; Spring 2005 advanced interdisciplinary study was enrolled in but not completed, resulting in an F.
- She did not complete the final project or earn the degree; in 2007 she sought refunds; mediation failed and an associate dean found meritless claims; she filed suit.
- In district court she was allowed to amend to join the university president and add a due-process claim; the court dismissed her breach-of-contract and promissory-estoppel claims as educational malpractice and granted summary dismissal, and dismissed the due-process claim for failure to state a claim.
- Appellant appeals, challenging the dismissals of both her complaint and amended complaint; the court affirms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Were contract and promissory-estoppel claims properly dismissed? | Zinter argues the U breached promises made to obtain her degree. | U contends claims require evaluating educational processes, which is not proper. | Yes; claims dismissed as educational malpractice. |
| Were the due-process claims properly dismissed? | Zinter seeks restitution and transcript remedies, not monetary damages. | U argues no cognizable due-process claim and no basis for equitable relief. | Yes; claims dismissed for failure to state a claim. |
Key Cases Cited
- Alsides v. Brown Inst., Ltd., 592 N.W.2d 468 (Minn.App.1999) (educational-malpractice claims not recognized; deference to educational decisions)
- Bd. of Curators v. Horowitz, 435 U.S. 78 (U.S. Supreme Court 1978) (judicial restraint in academic disciplinary matters)
- Deli v. Univ. of Minn., 578 N.W.2d 779 (Minn.App.1998) (promissory estoppel requires a clear promise and reliance)
- Cohen v. Cowles Media Co., 479 N.W.2d 387 (Minn.1992) (promissory estoppel elements; reliance and injustice standard)
- Glorvigen v. Cirrus Design Corp., 796 N.W.2d 541 (Minn.App.2011) (educational-malpractice-like analysis on academic instruction claims)