## Facts

- Beatrice Anthony enrolled at Syracuse University from September 1923 until October 6, 1926, in the Department of Domestic Science.
- At registration, Anthony signed cards agreeing to comply with university regulations and accepting enrollment subject to a “continuance” rule contained in the university catalog.
- The catalog rule stated that attendance was a “privilege,” and that the university could require a student’s withdrawal at any time for any reason the university deemed sufficient; specific charges might or might not be stated.
- The continuance rule was amended slightly before the 1924–1925 year, and Anthony signed later registration cards incorporating the amended language.
- On October 6, 1926, university officers dismissed Anthony without formal charges, telling her they had heard rumors, spoke to students in her sorority house, concluded she had caused trouble, and did not consider her “a typical Syracuse girl.”
- Anthony sued for breach of contract, alleging the dismissal was arbitrary and unjust; the trial court entered judgment for her.

## Issues

1. Whether a student who signs registration documents incorporating catalog rules is bound by those rules even if the student did not read them.
2. Whether a private university may, by contract, reserve discretion to require a student’s withdrawal at any time for any reason the university deems sufficient, with or without specific charges.
3. Whether courts may review and second-guess the sufficiency or fairness of a private university’s dismissal decision when the governing contract commits that decision to the institution.

## Decision

- The appellate court reversed the judgment for Anthony and dismissed the complaint.
- The court held that the registration cards and incorporated catalog provision formed part of the parties’ contract and bound Anthony.
- The university’s contractual reservation of discretion to require withdrawal for reasons it deemed sufficient was enforceable.
- Because the institution was treated as private, and the contract committed the sufficiency of reasons to the university’s judgment, the court would not interfere absent illegality or a clear public-policy bar.

## Legal Principles

- The student–private university relationship may be governed by contract terms contained in registration documents and incorporated catalog rules.
- A party who signs a contract incorporating referenced terms is generally bound by those terms absent fraud or misrepresentation.
- Where a private university’s contract reserves broad discretion to dismiss or require withdrawal, courts ordinarily will not substitute their judgment for the institution’s on internal disciplinary and suitability determinations, unless the action is unlawful or violates a clear public policy.
- Contractual language stating that specific charges may or may not accompany a withdrawal request can negate any implied contractual requirement of formal notice or charges as a condition of dismissal.

## Conclusion

The court held that Anthony’s signed registration agreements incorporated a catalog rule giving Syracuse University discretion to require withdrawal for reasons it deemed sufficient, and it declined to review the fairness of the university’s stated reasons; the trial judgment for Anthony was reversed and her contract claim dismissed.


Anthony v. Syracuse Univ., 224 A.D. 487, 231 N.Y.S. 435 (N.Y. App. Div. 4th Dep’t 1928)