Case name: Kadakia v. Rutgers, The State University of New Jersey, No. 13-2450 (D. N.J. 03/24/15).
Ruling: The U.S. District Court, District of New Jersey dismissed a former student’s suit against Rutgers University.
What it means: A student charged with poor academic performance is merely entitled to an informal faculty evaluation.
Summary: Sarin Kadakia was accepted into a combination undergraduate and medical school curriculum at the Robert Wood Johnson Medical School at Rutgers University in 2007.
In his second year, Kadakia failed two courses. He successfully remediated one of them but failed the other a second time. After a hearing, the school’s academic standing committee placed him on academic warning for the remainder of his time in medical school.
In his third year, Kadakia received grades of conditional pass in two clerkships because he failed the national exam in those subjects. Kadakia remediated those grades by retaking and passing the exams.
However, the physicians who observed Kadakia during a medicine clerkship expressed concern over his lack of clinical knowledge and his inability to apply that knowledge to patients. Accordingly, Kadakia received a failing grade, and his appeals were denied.
After a hearing at which Kadakia appeared with counsel, he was dismissed because of persistent academic difficulties.
Kadakia filed a suit claiming he had been denied due process. Rutgers filed a motion for summary judgment.
Assuming for the sake of argument that Kadakia had a constitutional right to continue his studies, the district judge held that he failed to prove the dismissal was beyond the pale of reasoned academic decision-making because there was ample evidence Rutgers properly dismissed him for poor academic performance.
The judge also ruled Kadakia had been afforded far greater procedural due process than the “informal faculty evaluation” that was constitutionally required, because two hearings were held — and he was represented by counsel at one of them — and he had exercised his appellate rights.