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
- 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?
- 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.