## Facts

- Rubye Wilson, about 60 years old, applied to the University of Arizona Graduate College for admission to the M.F.A. program in studio painting and submitted required slides of her work.
- The Art Department used a faculty committee to review applications in small groups as they arrived; members evaluated slides and the applicant’s artistic promise without a formal checklist of “objective” criteria.
- The department rejected Wilson’s application, stating that facilities were already committed and that her work did not fit the department’s aesthetic attitudes.
- Faculty evaluators described Wilson’s work as professionally executed and technically accomplished but too conventional and lacking originality and creative promise for the program.
- Wilson contended the denial was arbitrary and unreasonable in light of her academic record, prior study, awards, and sales of her artwork.
- Some testimony supported the faculty’s concerns, including criticism of the work and evidence of difficulties teaching Wilson.

## Issues

1. Whether the Art Department’s denial of Wilson’s M.F.A. application, based on qualitative faculty assessment and without fixed objective criteria, was so arbitrary, capricious, or unreasonable that a court could order her admission.
2. Whether a rolling, grouped-review admissions process could be treated as irrational or unlawfully unfair when fewer spaces remained later in the cycle.
3. Whether the trial court improperly substituted its judgment for the faculty’s academic judgment in ordering admission.

## Decision

- The Court of Appeals reversed the trial court.
- The court held the denial of admission was not arbitrary, capricious, or unreasonable.
- The court vacated the order compelling Wilson’s admission and upheld the university’s decision.
- The court approved the department’s rolling review method as rational and valid and found no showing that timing affected the outcome.
- The court concluded the trial court erred by reweighing artistic merit and replacing faculty judgment with judicial judgment.

## Legal Principles

- Judicial review of public-university academic admissions decisions is highly limited; courts may intervene only upon proof of bad faith, fraud, discrimination, or action that is arbitrary, capricious, or wholly lacking a rational basis.
- In fields requiring expert and subjective evaluation (such as fine arts), reliance on qualitative faculty judgment does not become unlawful merely because there are no rigid, quantified admission criteria.
- Courts may assess whether the process has a rational structure and is applied in good faith, but they may not determine an applicant’s academic or artistic qualifications.

## Conclusion

The appellate court held that good-faith faculty evaluation of artistic potential provided a rational basis for denying admission, and that a court cannot compel admission simply because it disagrees with the academic judgment or prefers more “objective” criteria.


Arizona Bd. of Regents v. Wilson, 539 P.2d 943 (Ariz. Ct. App. 1975)