## Facts

- Frederick J. Haberle enrolled in July 1979 in the University of Alabama at Birmingham (UAB) chemistry graduate program seeking a Ph.D.
- Soon after entry, Haberle received a written document titled “Requirements for Degree in Chemistry,” listing Ph.D. requirements: (1) completion of course work, (2) competence in two foreign languages, (3) successful completion of the qualifying (comprehensive) examination, (4) presentations at two seminars, and (5) completion of a dissertation.
- During his enrollment, Haberle completed the required coursework, demonstrated competency in two foreign languages, and presented at one graduate seminar.
- Haberle registered for dissertation research beginning in the winter term of 1980–81 and continued dissertation research through the summer term of 1983–84.
- In July 1981, Haberle’s graduate committee met to review his curriculum and the qualifying-exam requirement; it noted the exam remained outstanding and planned to meet again to consider a research proposal and set an exam date.
- The committee did not meet again until January 1984. At that meeting, the committee stated Haberle still had to take the qualifying examination and told him to do so promptly.
- Haberle objected, arguing the exam should have been required before he began dissertation research years earlier.
- No student had ever been awarded a Ph.D. in chemistry at UAB without passing the qualifying examination.
- Haberle took the qualifying examination in 1984, failed, retook it, and failed again. UAB dismissed him from the Ph.D. program.
- Haberle pursued an internal grievance challenging the dismissal; the grievance was denied.
- Haberle sued UAB and various faculty and administrators under 42 U.S.C. § 1983, alleging the dismissal was arbitrary and violated procedural and substantive due process under the Fourteenth Amendment.
- The federal district court granted summary judgment to UAB and the individual defendants, and Haberle appealed.

## Issues

1. Assuming Haberle had a constitutionally protected interest in continued enrollment, did UAB’s academic-dismissal process satisfy procedural due process when it required the qualifying exam and dismissed him after two failures?
2. Did dismissing Haberle after two qualifying-exam failures—despite the committee’s multi-year delay in setting the exam—constitute a substantial departure from accepted academic norms, violating substantive due process?

## Decision

- The Eleventh Circuit affirmed the district court’s grant of summary judgment for UAB and the individual defendants.
- Treating the matter as an academic dismissal, the court held that procedural due process in this setting requires a decision-making process that is careful and deliberate, not a trial-type hearing.
- The court concluded UAB’s actions met the careful-and-deliberate standard: Haberle had written notice of the qualifying-exam requirement, was told to take it, was allowed to take it twice, and received internal review through the grievance process.
- The court rejected the substantive due process claim because enforcing a long-standing, universally applied qualifying-exam requirement—and dismissing a student who twice failed it—was not a substantial departure from accepted academic norms, even if the program’s timing and supervision were imperfect.

## Legal Principles

- Courts give substantial deference to academic judgments about student progress and degree requirements and are reluctant to second-guess faculty evaluations of academic competence.
- In academic dismissals, procedural due process does not require a formal adversarial hearing; the constitutional question is whether the institution’s decision was careful and deliberate, with notice and an opportunity for the student to respond in an informal manner.
- For substantive due process challenges to academic decisions, judicial intervention is limited to situations showing a substantial departure from accepted academic norms indicating the decision was not an exercise of professional academic judgment.
- A written, consistently applied degree requirement—such as a qualifying examination historically required of all Ph.D. candidates—supports the conclusion that dismissal for failing that requirement is academic and non-arbitrary.
- Administrative delay or less-than-ideal advising does not, by itself, transform enforcement of a standard academic requirement into a constitutional violation.

## Conclusion

The Eleventh Circuit held that UAB’s dismissal of Frederick Haberle from its Ph.D. chemistry program after he twice failed the required qualifying examination was an academic decision reached through a careful and deliberate process and did not amount to a substantial departure from accepted academic norms; therefore, it did not violate procedural or substantive due process, and summary judgment for UAB was affirmed.


Haberle v. University of Alabama in Birmingham, 803 F.2d 1536 (1986)