Mark D. Hall v. University of Minnesota, 530 F. Supp. 104 (1982)

Facts

  • Mark D. Hall was a student and varsity men’s basketball player at the University of Minnesota.

  • Hall was enrolled in a non-baccalaureate program at the University’s main campus and had accumulated about 90 credits.

  • Under Big Ten Conference academic rules, Hall’s grade point average and credits satisfied conference standards, but he also needed to be enrolled in a University degree program to remain eligible to compete.

  • To satisfy the degree-program requirement and keep playing, Hall applied to the University’s University Without Walls (UWW), a nontraditional degree program within the University system.

  • UWW had distributed written materials stating that admissions would be determined based on the information submitted in the application and decided through an admissions-committee process.

  • Based on Hall’s application materials, the UWW admissions committee approved his application.

  • After the committee’s approval, UWW’s program leadership intervened and ensured that Hall’s application was rejected—an unusual step compared to typical admissions practice.

  • The intervention followed information supplied by the Dean of the General College that raised concerns about Hall’s academic record and conduct, including allegations that:

    • Hall received A grades in courses in which he was not enrolled;
    • his work required heavy monitoring;
    • he submitted work done by others as his own; and
    • transcript withdrawals were originally failing grades.

  • Hall alleged that the University’s reversal of the committee’s approval departed from UWW’s published admissions approach and deprived him of due process.

  • Hall sought injunctive relief in federal court ordering the University to admit him to a degree program so that his Big Ten eligibility would be restored.

Issues

  1. Whether Hall had a constitutionally protected property interest in admission to UWW (or another University degree program) based on UWW’s written admissions materials and the admissions committee’s approval.
  2. Whether Hall had a constitutionally protected liberty or property interest in continued participation in intercollegiate basketball (and related professional prospects) sufficient to trigger Fourteenth Amendment due process protection.
  3. Whether the University’s reversal of the admissions committee’s approval, and its reliance on outside information about Hall’s record, amounted to a denial of due process warranting a court-ordered injunction requiring admission.

Decision

  • The court denied Hall’s request for injunctive relief ordering the University to admit him to a degree program.
  • The court concluded Hall did not establish a constitutionally protected property interest in UWW admission.
  • The court also concluded Hall did not establish a constitutionally protected liberty or property interest in intercollegiate athletic participation.
  • Because no protected interest was shown, the court found no Fourteenth Amendment due process violation and declined to override the University’s admissions decision.

Legal Principles

  • A Fourteenth Amendment due process claim requires a protected liberty or property interest; a property interest exists only when an independent source (such as state law, formal rules, or a clear mutual understanding) gives a person a legitimate claim of entitlement, not merely a hope or expectation.
  • University admissions decisions are generally discretionary; general statements in catalogs or pamphlets about admissions procedures do not, without more, create a guaranteed entitlement to admission.
  • Participation in intercollegiate athletics, even when it affects future opportunities, is not ordinarily treated as a constitutionally protected liberty or property interest.
  • A university’s departure from its usual internal procedures, standing alone, does not become a federal due process violation unless the plaintiff first shows a protected interest that due process safeguards.
  • Federal courts are reluctant to act as admissions authorities and will not order admission absent a clear constitutional or statutory violation.

Conclusion

The district court refused to order the University of Minnesota to admit Mark D. Hall to UWW or any other degree program because Hall failed to show a constitutionally protected entitlement to program admission or to continued athletic eligibility, and without such an interest, the University’s unusual reversal of the admissions committee’s approval did not amount to a Fourteenth Amendment due process violation.