## Facts

- The University of Michigan awarded Wilson W. Crook III a Master of Science degree based on a thesis claiming discovery of a new mineral, supported by microprobe data and a university computer program’s output.
- Faculty later suspected the thesis data were fabricated, citing computer time logs inconsistent with the volume of reported results, the apparent implausibility of the data, and similarities to a known synthetic compound.
- The university notified Crook in writing that he was charged with fabricating thesis data and that his degree could be revoked.
- An ad hoc faculty disciplinary committee provided Crook the supporting documents, received his written response, and held a hearing where Crook attended with counsel, presented witnesses and evidence, and personally questioned witnesses (counsel was not permitted to conduct formal cross-examination).
- The committee found Crook committed fraud but did not recommend a sanction; subsequent university authorities recommended revocation.
- Crook sued under 42 U.S.C. § 1983 to stop rescission; after denial of a preliminary injunction, the Board of Regents voted to rescind the degree, accepting the fraud finding and revocation recommendation.

## Issues

1. Whether the University of Michigan’s Board of Regents had authority to revoke an academic degree previously awarded when the degree was procured by fraud.
2. Whether the procedures used to revoke Crook’s degree satisfied procedural due process under the Fourteenth Amendment.

## Decision

- The court held the Regents had authority to revoke a degree obtained by fraud.
- The court held the university’s notice-and-hearing process satisfied procedural due process.
- The court vacated the district court’s judgment for Crook and remanded with instructions to dismiss the complaint.

## Legal Principles

- A public university’s governing board may revoke an academic degree if the institution determines the degree was obtained through fraud, as part of its authority over academic matters and the integrity of its credentials.
- Revocation of a degree implicates due process protections, but the required procedures are flexible and context-dependent rather than strictly trial-like.
- In the academic discipline context, due process generally requires timely notice of the specific charge and potential sanction, access to the supporting evidence, and a meaningful opportunity to respond at a fair hearing; full adversarial procedures (including counsel-led cross-examination) are not constitutionally required.

## Conclusion

A public university may rescind a previously conferred degree upon a substantiated finding of fraud, and a structured but non-judicial disciplinary process providing notice, access to evidence, and a meaningful opportunity to be heard can satisfy procedural due process.


Crook v. Baker, 813 F.2d 88 (6th Cir. 1987)