## Facts

- Benjamin Metsch, then a student at Columbia University, applied for admission to the University of Florida College of Law for the fall 1989 entering class.
- Based on a computer projection derived from his undergraduate GPA and LSAT score, Metsch did not receive automatic admission.
- The law school placed his application in a “hold” category for further review by the Faculty Admissions Committee.
- The Faculty Admissions Committee reviewed “hold” applications by evaluating the application, transcripts, personal statement, evaluative letters, and other file materials; of roughly 900 “hold” files, about 163 applicants received offers of admission.
- In April 1989, the University of Florida informed Metsch that he was not admitted.
- In May 1989, Metsch wrote to the law school requesting (1) reasons for the denial, (2) reconsideration, and (3) a formal administrative hearing under section 120.57(1), Florida Statutes (1987), asserting that the University (a state agency) had determined his “substantial interests.”
- The University reconsidered the application, reaffirmed the denial, explained that other candidates presented more competitive files, described the admissions process, and suggested that Metsch reapply for the spring 1990 term.
- On May 10, 1989, the University’s Interim President denied Metsch’s request for an administrative hearing.
- Metsch appealed the denial of a hearing to the Florida Third District Court of Appeal.

## Issues

1. Did the University of Florida’s denial of Metsch’s law-school admission application entitle him to a formal administrative hearing under section 120.57(1), Florida Statutes (1987), including whether the denial determined his “substantial interests” and whether any statutory exemption applied?

## Decision

- The Third District Court of Appeal affirmed the University of Florida’s denial of Metsch’s request for a formal administrative hearing.
- The court concluded that Metsch’s interest in admission amounted to a hope or unilateral expectation rather than a substantial interest that triggers section 120.57(1).
- The court also relied on the statutory exemption in section 120.57(5), which states that section 120.57 does not apply to proceedings in which the substantial interests of a student are determined by the State University System.

## Legal Principles

- Section 120.57(1), Florida Statutes (1987), provides for formal administrative hearing procedures only in proceedings where an agency determines a party’s substantial interests, unless an exemption applies.
- A desire to obtain a discretionary benefit—such as admission to a competitive academic program—does not, by itself, create a substantial interest for purposes of invoking formal hearing rights under the Florida APA.
- Section 120.57(5), Florida Statutes (1987), excludes from section 120.57 proceedings in which the substantial interests of a student are determined by the State University System.
- Courts will not require a formal APA evidentiary hearing merely because an applicant disputes the outcome of an academic admissions decision, where the applicant lacks a legally protected entitlement to admission and the statute removes such matters from section 120.57.

## Conclusion

Metsch v. University of Florida holds that a rejected applicant to the University of Florida College of Law was not entitled to a formal hearing under section 120.57(1) because the denial of admission did not determine a qualifying substantial interest, and, in any event, section 120.57(5) exempts proceedings involving the substantial interests of students within the State University System; the order denying a hearing was affirmed.


Metsch v. University of Florida, 550 So. 2d 1149 (1989)