## Facts

- Meyer Blatt attended the University of Southern California School of Law as a night student (1961–1967), graduated in June 1967, and was admitted to the California bar.
- The Order of the Coif is a national honorary legal society with a chapter at USC; membership recognizes high scholastic achievement and is limited to a small portion of graduates.
- Blatt alleged that members of the local selection committee represented that if he graduated in the top 10% of his class, he would be “eligible for election” to the Order.
- Blatt graduated fourth in a class of 135 and alleged he had additional academic honors and a strong reputation for integrity and character.
- Blatt was not elected and alleged the chapter applied a policy limiting eligibility to students who served on Law Review and completed their assignments.
- Blatt claimed the Law Review-related policy was adopted after the initial statements, applied arbitrarily and discriminatorily, and inconsistently applied to other students with lower standing.
- Blatt sought declaratory and injunctive relief compelling his election to the Order of the Coif.

## Issues

1. Whether a court may review and overturn a private university-affiliated honorary society’s selection decision and compel election based on alleged arbitrariness and discrimination.
2. Whether statements that a student would be “eligible for election” upon meeting a class-rank threshold create an enforceable contract or support promissory estoppel requiring the society to elect the student.

## Decision

- The Court of Appeal affirmed the judgment of dismissal after a general demurrer was sustained without leave to amend.
- The court held that a refusal to elect a student to an honorary academic society is not the type of interest warranting judicial intervention because it does not control the legal right to practice law or earn a livelihood.
- The court held the alleged statements regarding being “eligible for election” did not amount to a promise of membership and did not create an enforceable contract.
- The court held promissory estoppel was not established because the alleged reliance (working hard and achieving high grades) was not a distinct, definite, and substantial detriment attributable to a promise of election.

## Legal Principles

- Courts generally will not compel membership decisions of private, voluntary, honorary, or academic organizations when the decision affects prestige rather than access to a profession or employment.
- Judicial review is more likely when exclusion from an association effectively bars a person from practicing a trade or profession; honorary distinctions that confer reputational advantages alone do not trigger similar intervention.
- A representation that a person will be “eligible for election” is not, without more, a definite promise to confer membership and does not form an enforceable contract.
- Promissory estoppel requires a clear promise and reliance amounting to definite and substantial action or forbearance; striving for academic success that independently benefits the student is insufficient to compel an honorary award.

## Conclusion

The court declined to second-guess or judicially compel an academic honorary society’s election decision and held that alleged assurances of “eligibility” based on class rank did not create contractual or promissory-estoppel grounds to mandate membership.


Blatt v. Univ. of S. Cal., 5 Cal. App. 3d 935 (Ct. App. 1970)