Justia Contracts Opinion Summaries

At the outset of the COVID-19 pandemic in March 2020, IIT, a nonprofit higher education institution, suspended all in-person instruction, moved all classes online, and restricted access to campus facilities. IIT did not refund tuition or mandatory fees to its students. Before the pandemic, IIT undergraduates were not permitted to register for an online class without special approval and were required to live on campus. Hernandez, a student who paid tuition and fees for the Spring 2020 semester, filed a purported class action, alleging that an express or implied contract was formed under which the university promised to provide in-person instruction, services, and resources, in exchange for tuition and compulsory fees, citing Activity Fees, Student Services Fees, Professional Co-Curricular Fees, and Studio Fees. He also raised an unjust enrichment theory, based on IIT’s retention of students’ full tuition and fees.The district court dismissed, finding that Hernandez failed to identify any specific promise to provide in-person, on-campus instruction to support a breach-of-contract claim and that Hernandez failed to state a claim for unjust enrichment. While his appeal was pending, the Seventh Circuit decided "Gociman," finding that Loyola University students adequately stated claims for breach of an implied contract under Illinois law. The Seventh Circuit reversed the dismissal of Hernandez’s case, finding no meaningful distinctions between his case and Gociman. View "Hernandez v. Illinois Institute of Technology" on Justia Law

Plaintiff enrolled in a Doctor of Education degree program at Grand Canyon University. Plaintiff claims that he did not complete his degree because, despite representing that students can finish the program in 60 credit hours, Grand Canyon makes that goal impossible with the aim of requiring students to take and pay for additional courses. Plaintiff also claims that he was not provided with the faculty support promised by Grand Canyon. According to Plaintiff Grand Canyon’s failure to provide dissertation support is designed to require students to take and pay for additional courses that would allow them to complete the dissertation. Plaintiff filed claims alleging breach of contract, intentional misrepresentation, and unjust enrichment. He also asserted claims under the Arizona Consumer Fraud Act. The district court dismissed the complaint in its entirety with prejudice under Rule 12(b)(6).   The Eleventh Circuit affirmed the district court’s dismissal of Plaintiff’s claims for violations of the ACFA, intentional misrepresentation, and unjust enrichment. The court reversed in part the dismissal of Plaintiff’s claims for breach of contract and breach of the covenant of good faith and fair dealing. The court explained that though Grand Canyon did not contractually promise Plaintiff that he would earn a doctoral degree within 60 credit hours, he has plausibly alleged that it did agree to provide him with the faculty resources and guidance he needed to complete his dissertation. Insofar as he asserts that Grand Canyon promised and failed to meaningfully provide him with the faculty support necessary to complete his dissertation, he has sufficiently alleged breach of contract and breach of the covenant of good faith and fair dealing. View "Donrich Young v. Grand Canyon University, Inc., et al." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court affirming the decision of the Sibley-Ocheyedan Community School District to terminate Plaintiff's teaching contract, holding that the school district violated the law when it terminated Plaintiff's contract.Administrators at the school district required Plaintiff, a high school teacher, to participate in an "intensive assistance program" described in Iowa Code chapter 284. The school district's policy implementing chapter 284 required teachers to participate in the program at minimum six months and at most twelve months. The school district, however, fired Plaintiff before she'd been given six months to carry out her responsibilities in the program. The district court affirmed the school board's decision, but the court of appeals reversed. The Supreme Court affirmed, holding that the school district unlawfully terminated Plaintiff's contract before giving her the requisite period to participate in the intensive assistance program. View "Braaksma v. Bd. of Directors of Sibley-Ocheyedan Community School District" on Justia Law

Two former students of Tulane University, on behalf of a putative class of current and former students, sued the University for failing to provide a partial refund of tuition and fees after Tulane switched from in-person instruction with access to on-campus services to online, off-campus instruction during the COVID-19 pandemic. The district court agreed with Tulane that the student's complaint should be dismissed for failure to state a claim.   The Fifth Circuit reversed and remanded. The court concluded that the claim is not barred as a claim of educational malpractice because the Students do not challenge the quality of the education received but the product received. Second, the court rejected Tulane’s argument that the breach-of-contract claim is foreclosed by an express agreement between the parties because the agreement at issue plausibly does not govern refunds in this circumstance. And third, the court concluded that Plaintiffs have not plausibly alleged that Tulane breached an express contract promising in-person instruction and on-campus facilities because Plaintiffs fail to point to any explicit language evidencing that promise. But the court held that Plaintiffs have plausibly alleged implied-in-fact promises for in-person instruction and on-campus facilities. Moreover, the court found that the Students’ alternative claim for unjust enrichment may proceed at this early stage. Finally, genuine disputes of material fact regarding whether Plaintiffs saw and agreed to the A&DS preclude reliance on the agreement at this stage. Thus, Plaintiffs have plausibly alleged a claim of conversion. View "Jones v. Admin of the Tulane Educ" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the summary judgment entered by the Cuyahoga County Court of Common Pleas in favor of Warrensville Heights in this real property dispute, holding that the agreement between the parties in this case was valid and enforceable.The Beachwood City School District Board of Education sought approval from the state board of education for a transfer of territory it annexed in 1990 to the Beachwood City School District. The Warrensville Heights City School District Board of Education, whose district the annexed territory was a part of, objected. In 1997, Beachwood and Warrensville Heights agreed that the territory would not transfer to the Beachwood City School District but that the districts would share the tax revenue generated from real property located within the territory. The court of common pleas granted summary judgment for Warrensville Heights, concluding that the parties' agreement was not valid. The court of appeal reversed. The Supreme Court affirmed, holding that the 1997 agreement required neither approval nor a fiscal certificate and therefore was valid and enforceable. View "Beachwood City School District Bd. of Education v. Warrensville Heights City School District Bd. of Education" on Justia Law

The Supreme Court dismissed this appeal from a district court's order denying injunctive relief, holding that this Court lacked jurisdiction to hear the appeal.Plaintiffs were ten students at Creighton University who brought this petition seeking to enjoin Creighton from administratively withdrawing students who did not comply with its COVID-19 vaccine policy. After a hearing, the district court denied the petitions, concluding that Plaintiffs failed to show irreparable harm or a likelihood of success on the merits. Plaintiffs appealed. The Supreme Court dismissed the appeal, holding that the court's denial of a temporary injunction was not a final order, and therefore, this Court lacked jurisdiction over the appeal. View "Ramaekers v. Creighton University" on Justia Law

In this COVID-19 pandemic-related case, the Seventh Circuit vacated in part the judgment of the district court granting Loyola University of Chicago's motion to dismiss this complaint brought by Plaintiffs, three undergraduate students, for breach of contract and unjust enrichment, holding that Plaintiffs pled enough to withstand dismissal for failure to state a claim and that Plaintiffs were entitled to leave to amend to save their alternative claim for unjust enrichment.As a result of the pandemic, Loyola suspended all in-person instruction during the Spring 2020 semester, curtailed access to campus facilities, and moved all instruction online. Plaintiffs brought a putative class action lawsuit against Loyola, arguing that the decision to shut down Loyola's campus deprived them of promised services, such as in-person instruction and access to on-campus facilities, in exchange for tuition and fees. The district court granted Loyola's motion to dismiss for failure to state a claim. The Seventh Circuit reversed in part, holding (1) Plaintiffs sufficiently pled a claim for breach of an implied contract under Illinois law; and (2) Plaintiffs adequately pled an unjust enrichment claim in the alternative. View "Gociman v. Loyola University of Chicago" on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff's complaint against Harvard University for breach of contract and other related claims, holding that the district court erred in dismissing Plaintiff's breach of contract claim.The day before Plaintiff was about to graduate from Harvard three female Harvard students accused him of sexual assault. Following a disciplinary hearing, Harvard withheld Plaintiff's undergraduate degree. Plaintiff sued, and the district court dismissed the complaint for failure to state a claim. The First Circuit reversed in part, holding (1) at the pleadings stage, Plaintiff's allegations, taken as true, stated a plausible breach of contract claim; and (2) the district court properly dismissed the remaining counts of Plaintiff's complaint. View "Sonoiki v. Harvard University" on Justia Law

Keles was admitted into Rutgers’s Civil and Environmental Engineering (CEE) Department’s graduate program and received his M.S. degree in 2014. While pursuing this degree, Keles expressed his interest in continuing his studies as a Ph.D. student. To continue their studies as Ph.D. students, M.S. students in the CEE Department must submit a “Change-in-Status” form, identifying advisors and describing their research plans. At the end of the M.S. program, Keles submitted an incomplete Change-in-Status form. Keles disputed that he needed to submit a completed Change-in-Status form due to his claimed enrollment as an M.S.-Ph.D. student. Members of the CEE Department and the University’s administration informed him that he needed to satisfy the admission prerequisites. Keles neither found an advisor nor submitted a completed form but sought to register for classes in 2015. Rutgers’s Administration informed Keles that his lack of academic standing prevented him from registering.Keles sued, alleging contract, tort, statutory, and due process claims. The Third Circuit affirmed the dismissal of his suit, finding that Rutgers adhered to its own policies and did not act in bad faith. All M.S. students were subject to the same departmental requirements. Rutgers afforded Keles sufficient process and did not venture “beyond the pale of reasoned academic decisionmaking.” View "Keles v. Bender" on Justia Law

The Universities responded to the COVID-19 pandemic by transitioning from in-person to online learning and largely shutting down campus activities. Students and parents sued, claiming that the Universities violated contractual commitments when they transitioned to online educational activities and declined to refund any portion of their students’ tuition and fees or, in the alternative, that the transitions unjustly enriched the Universities.The D.C. Circuit affirmed the dismissal of conversion claims and claims that the Universities breached express contracts promising in-person educational instruction, activities, and services. They did not plausibly allege a possessory interest in a specific, identifiable fund of money. The cited materials cited do not support the express contract claims. Reversing in part, the court held that the complaints plausibly allege that the Universities breached implied-in-fact contracts for in-person education, on-campus activities, and services. The plaintiffs should be allowed to raise their alternative theory of unjust enrichment. The court also reinstated a claim under the D.C. Consumer Protection Procedures Act. The court acknowledged that the Universities will likely have compelling arguments to offer that the pandemic and resulting government shutdown orders discharged their duties to perform these alleged promises, which must be addressed by the district court. View "Shaffer v. George Washington University" on Justia Law