## Facts

- Robert Hall was a medical student at the Medical College of Ohio at Toledo (MCO), a state-created institution substantially funded by Ohio and governed by a governor-appointed board.
- MCO charged Hall with academic dishonesty (cheating) and provided notice of the charge.
- A faculty panel held a hearing at which Hall could appear and defend himself; he was not permitted to have an attorney represent him at the hearing.
- The faculty panel voted to dismiss Hall, issued a report, and Hall pursued an administrative appeal to the college president, who upheld the dismissal.
- Hall sued MCO and various administrators and faculty in federal court, seeking damages and reinstatement and alleging racial discrimination and due process violations under 42 U.S.C. §§ 1981, 1983, and 2000d, and the Constitution.

## Issues

1. Whether MCO and MCO officials sued in their official capacities were immune from suit in federal court under the Eleventh Amendment for claims seeking damages and reinstatement.
2. Whether MCO officials sued in their individual capacities were entitled to qualified immunity from damages for their roles in the dismissal process.
3. Whether the summary-judgment record showed a triable claim of racial discrimination or denial of due process sufficient to warrant relief.

## Decision

- The Sixth Circuit affirmed summary judgment for all defendants and dismissal of the complaint in full.
- The court held MCO was an arm of the State of Ohio; claims that would impose liability payable from state funds were barred by the Eleventh Amendment, including official-capacity claims.
- The court held the individual defendants had qualified immunity from personal liability for damages for actions within the scope of their official duties.
- The court affirmed dismissal of Hall’s claim for reinstatement on the record presented.

## Legal Principles

- The Eleventh Amendment bars federal suits by private parties seeking retrospective legal or equitable liability payable from state funds when the state is the real party in interest, including suits nominally against state officials in their official capacities.
- A state-created, state-funded public institution governed by state-appointed trustees may be treated as an arm of the state for Eleventh Amendment purposes.
- Public officials are protected by qualified immunity from damages when their conduct does not violate clearly established constitutional rights of which a reasonable official would have known.
- In higher-education discipline, notice of charges, an opportunity to be heard before institutional decisionmakers, and an internal appeal may satisfy due process; the absence of attorney representation at such a hearing does not, by itself, violate clearly established due process law.

## Conclusion

The Sixth Circuit concluded that MCO functioned as an arm of Ohio and was immune from federal claims seeking monetary relief payable from state funds, that school officials were shielded by qualified immunity from damages, and that the disciplinary procedures and evidentiary record did not support Hall’s due process or race-discrimination claims, warranting affirmance of summary judgment and dismissal of all requested relief, including reinstatement.


Hall v. Med. Coll. of Ohio at Toledo, 742 F.2d 299 (6th Cir. 1984)