## Facts

- Charlotte Horowitz was a student at the University of Missouri–Kansas City Medical School.
- The school evaluated students through a Council of Evaluation, which could recommend probation or dismissal, subject to review by a faculty Coordinating Committee and final approval by the Dean.
- Faculty repeatedly reported dissatisfaction with Horowitz’s clinical performance, beginning with a pediatrics rotation.
- The Council advanced her to her final year on probation but later concluded she should not be considered for graduation absent radical improvement and that dismissal should follow if performance did not change.
- As an “appeal,” Horowitz was examined by seven practicing physicians; their recommendations were mixed, and the Council reaffirmed its judgment.
- After continued negative clinical evaluations, the Council recommended dismissal; the Coordinating Committee and Dean approved, and the Provost sustained the decision on appeal.
- Horowitz sued under 42 U.S.C. § 1983, claiming a Fourteenth Amendment due process violation based on the absence of a formal hearing.
- The district court ruled for the university after trial; the Eighth Circuit reversed; the Supreme Court granted certiorari.

## Issues

1. Whether a public university violates the Fourteenth Amendment Due Process Clause by dismissing a student for academic reasons without a formal hearing before the final decisionmaker.

## Decision

- The Supreme Court reversed the Eighth Circuit in a 6–3 decision.
- The Court held that Horowitz’s academic dismissal did not violate due process.
- The Court rejected a constitutional requirement of a trial-type hearing for academic dismissals.
- The Court concluded Horowitz had been adequately informed of faculty dissatisfaction and the risk to graduation and continued enrollment, and the school’s decisionmaking was careful and deliberate.

## Legal Principles

- Academic dismissals are procedurally distinct from disciplinary removals; due process does not generally require adversarial procedures (such as confrontation and cross-examination) for academic judgments.
- Academic evaluations involve expert, cumulative judgments that are poorly suited to formal hearing mechanisms designed for factfinding disputes.
- In the academic-dismissal context, due process is satisfied where the institution gives the student notice of academic deficiencies and the ultimate decision reflects careful and deliberate professional judgment.
- Courts should give substantial deference to faculty and institutional academic decisionmaking and should not require detailed, constitutionally mandated internal procedures for academic standards enforcement.

## Conclusion

A public medical school may dismiss a student for academic deficiencies without a formal hearing when the student has been informed of ongoing performance concerns and the decision to dismiss results from careful, deliberate academic evaluation.


Bd. of Curators of Univ. of Mo. v. Horowitz, 435 U.S. 78 (1978)