## Facts

- Foundation for Interior Design Education Research (FIDER) was the primary accrediting body for interior design education programs in the United States.
- Savannah College of Art & Design (SCAD) operated an interior-design program and applied to FIDER for accreditation in January 1995.
- FIDER conducted an on-site review in April 1995 using a three-member team of practitioners/educators.
- The team’s report praised aspects of SCAD’s program but recommended denial based on deficiencies in multiple “student achievement” areas.
- FIDER’s accreditation committee and board reviewed the report and SCAD’s responses, initially denied accreditation, and then provided internal reconsideration procedures.
- FIDER conducted a second site visit and additional internal review; after these steps, it again denied accreditation.
- SCAD alleged the accreditation process was biased, inconsistently applied, and motivated by anticompetitive forces; FIDER asserted it followed fair procedures and relied on substantial evidence.

## Issues

1. What standard of judicial review applies to a private accrediting agency’s denial of accreditation.
2. Whether FIDER’s denial of accreditation was arbitrary, unreasonable, or the product of unfair procedures.
3. Whether SCAD stated or proved federal antitrust claims based on FIDER’s role and the denial of accreditation.
4. Whether SCAD stated viable state-law claims for breach of contract, “common law due process,” breach of fiduciary duty, or fraud arising from the accreditation process.

## Decision

- The Sixth Circuit affirmed the district court in full.
- The court upheld summary judgment declaring that FIDER’s denial of accreditation did not violate SCAD’s rights.
- The court affirmed dismissal of SCAD’s counterclaims for antitrust violations, breach of contract, “common law due process,” breach of fiduciary duty, and fraud.
- The court concluded FIDER followed its established procedures, provided fair and impartial process, and based its decision on substantial evidence rather than arbitrariness or bad faith.

## Legal Principles

- Judicial review of private accreditation decisions is limited; courts do not reweigh educational judgments if the accreditor follows its procedures, affords fair process, and reaches a decision supported by substantial evidence.
- An accreditor’s good-faith application of educational standards, without more, does not constitute an unreasonable restraint of trade or monopolization; antitrust liability requires plausible market definition and harm to competition, not merely injury to one institution.
- Accreditation materials may create enforceable procedural expectations, but a contract claim requires showing the accreditor failed to provide the promised procedures or otherwise breached specific obligations.
- Constitutional due process constraints generally do not apply to private accreditors; any state-law fair-procedure obligation is satisfied by impartial procedures consistent with the accreditor’s rules.
- The accreditor–institution relationship is evaluative rather than fiduciary; dependence on accreditation does not, by itself, create fiduciary duties.
- Fraud claims require particularized allegations and proof of material misrepresentation, knowledge of falsity, and intent to deceive; disagreement with an accreditor’s evaluation is insufficient.

## Conclusion

The Sixth Circuit held that FIDER’s denial of SCAD’s accreditation was judicially reviewable only for basic procedural fairness and evidentiary support, and it affirmed because FIDER provided multiple levels of review, applied its standards through fair procedures, and relied on substantial evidence; SCAD’s antitrust and state-law counterclaims failed because they did not show unlawful restraints on competition, contractual breach, a fiduciary relationship, actionable fraud, or any lack of fair process.


Found. for Interior Design Educ. Rsch. v. Savannah Coll. of Art & Design, 244 F.3d 521 (6th Cir. 2001)