## Facts

- Alabama State College, a state-supported public institution, enrolled several African American students who participated in civil-rights demonstrations, including sit-ins and other off-campus protest activity.
- College and state education officials summarily expelled (or refused to readmit) several of these students.
- The expulsions occurred without written notice of specific charges, without an evidentiary hearing, and without a meaningful chance for the students to present a defense to the decisionmakers.
- The students filed suit in federal court alleging that expulsion from a public college without notice and hearing violated the Fourteenth Amendment’s Due Process Clause.
- The district court denied relief to the students, and the students appealed.

## Issues

1. Whether the Due Process Clause of the Fourteenth Amendment requires a state-supported college to provide notice and an opportunity to be heard before expelling students for misconduct.
2. If due process applies, what minimum procedures are constitutionally required in a public-college expulsion decision.

## Decision

- The Fifth Circuit reversed the district court and held that the students’ summary expulsions violated due process.
- Because the college and board acted as state actors, their disciplinary expulsions were subject to the Fourteenth Amendment.
- The court required, at minimum, notice of the specific grounds for expulsion and some meaningful opportunity for the student to present their side before expulsion.
- The court explained that a disciplinary hearing need not take the form of a full judicial trial, but it must provide a fair chance to respond to the allegations.
- The case was remanded for further proceedings consistent with these due process requirements.

## Legal Principles

- Disciplinary expulsion from a tax-supported college implicates a protected liberty and/or property interest because it can harm reputation and impair future educational and employment opportunities.
- A public college may not expel a student for misconduct without due process, including:
  - timely, meaningful notice of the specific charges or grounds; and
  - a hearing that provides a real opportunity to present a defense to an appropriate decisionmaking body.
- The hearing may be informal and need not include all features of a criminal or civil trial, but it must be conducted in a manner that is fair and allows the student to be heard before the sanction is imposed.
- Administrative interests in discipline and efficiency do not justify dispensing with the basic procedural safeguards of notice and an opportunity to be heard.

## Conclusion

The court held that public-college students facing expulsion are entitled to Fourteenth Amendment procedural due process, requiring notice of the allegations and a meaningful opportunity to be heard before the institution imposes the severe sanction of expulsion.


Dixon v. Alabama State Bd. of Educ., 294 F.2d 150 (5th Cir. 1961)