## Facts

- Gaurav Mangla applied to Brown University’s Graduate School and was admitted in 1993 as a “probationary special student,” a non-degree status allowing enrollment in graduate courses.
- An associate dean explained Mangla’s admission was probationary because he lacked the academic background in computer science and that admission to the degree program would require successful completion of computer science course work.
- Mangla completed substantial course work he believed satisfied most master’s degree requirements and was told to obtain a faculty advisor for a master’s project.
- Mangla obtained a letter from a professor stating Mangla “will be working under my supervision” for a master’s project; Mangla believed the letter confirmed or supported his admission to the master’s program.
- In 1995 Brown discontinued Mangla’s special-student status and informed him he had not been admitted to the computer science master’s program.
- Mangla submitted a formal application to the master’s program; the computer science faculty voted to recommend denial, and the Graduate Council unanimously upheld the denial.
- Mangla sued for breach of contract and promissory estoppel; after the evidence closed at trial, the district court granted judgment as a matter of law for Brown.

## Issues

1. Whether university publications and communications created a contract requiring Brown to admit Mangla to the computer science master’s program upon completion of course work and obtaining a faculty advisor.
2. Whether Brown made a clear and definite promise supporting promissory estoppel, and whether Mangla’s reliance on any such promise was reasonable.
3. Whether the evidence permitted a reasonable jury to find for Mangla, making judgment as a matter of law improper.

## Decision

- The First Circuit affirmed the judgment as a matter of law for Brown University.
- No reasonable jury could find an enforceable contractual obligation requiring admission to the master’s program based on Mangla’s special-student status, course completion, or the advisor letter.
- No reasonable jury could find a clear and definite promise by Brown sufficient for promissory estoppel, and any reliance on informal statements was not objectively reasonable given the written admissions requirements.
- The court rejected claims that Brown acted arbitrarily or in bad faith, noting the formal departmental review and Graduate Council affirmation of the denial.

## Legal Principles

- In disputes between a student and a university, contractual terms are generally drawn from official written materials (such as catalogs and formal policies), while academic and admissions judgments receive substantial judicial deference.
- Where institutional rules require that admission offers be made in a specific formal manner by a designated official, informal faculty or staff communications do not constitute admission and do not bind the institution.
- Satisfaction of prerequisites or completion of course work does not create an automatic right to admission absent a clear institutional commitment to admit upon completion.
- Promissory estoppel against a university requires a clear and definite promise and reasonable reliance; reliance is generally unreasonable when contrary to express written admissions procedures.

## Conclusion

The court held that Brown’s written admissions framework and Mangla’s non-degree status left the university discretion to deny admission, and that neither the course work nor a professor’s supervision letter created a contract or a clear promise requiring Mangla’s admission; accordingly, judgment as a matter of law for Brown was affirmed.


Mangla v. Brown Univ., 135 F.3d 80 (1st Cir. 1998)