## Facts

- Professional Massage Training Center, Inc. (PMTC) operated a massage-therapy training school and held accreditation from the Accreditation Alliance of Career Schools and Colleges (ACCSC) since 2000, renewed in 2005.
- In 2010, PMTC applied for reaccreditation, which was necessary for its students’ eligibility for federal Title IV student-aid funding.
- After an on-site evaluation and follow-up review, ACCSC identified multiple deficiencies, including management continuity, strategic planning, staff professional development, student achievement and employment outcomes, and verification of faculty credentials.
- ACCSC denied PMTC’s reaccreditation application after providing notice, receiving responses, and documenting its concerns during the review process.
- PMTC pursued an internal appeal to an ACCSC appeals panel, which affirmed the denial.
- PMTC sued in federal district court alleging unfairness characterized as “due process” violations and asserting state-law claims for breach of contract, negligence, and tortious interference.
- Following a bench trial, the district court effectively reexamined the accreditation decision and ordered reinstatement of accreditation and awarded damages, while dismissing the state-law claims.

## Issues

1. What standard governs federal court review of a private accrediting agency’s denial of accreditation: de novo review or a highly deferential arbitrary-and-capricious/substantial-evidence test?
2. Under the proper standard, was ACCSC’s denial of PMTC’s reaccreditation arbitrary, capricious, an abuse of discretion, or unsupported by substantial evidence?
3. Did alleged bias by ACCSC decisionmakers invalidate the denial or justify reduced deference?
4. Were PMTC’s state-law claims for breach of contract, negligence, and tortious interference properly dismissed?

## Decision

- The Fourth Circuit held the district court erred by conducting de novo-style review and substituting its judgment for the accreditor’s professional judgment.
- The court applied a deferential standard asking whether the decision was arbitrary, unreasonable, or an abuse of discretion and whether it was supported by substantial evidence.
- Under that standard, the court held ACCSC’s denial was supported by the record and was neither arbitrary nor capricious.
- The court found the evidence did not show disqualifying bias or unfair procedure sufficient to invalidate ACCSC’s decision.
- The court reversed the order reinstating accreditation and the damages award, affirmed dismissal of the state-law claims, and remanded.

## Legal Principles

- Judicial review of private accrediting decisions is highly deferential; courts may not conduct de novo review or replace an accreditor’s educational and institutional judgments with their own.
- An accreditation decision will be upheld if it is not arbitrary, unreasonable, or an abuse of discretion and is supported by substantial evidence.
- The reviewing court’s role is to ensure basic fairness (notice, an opportunity to respond, and reasoned decisionmaking), not to reassess academic criteria or institutional quality.
- Allegations of bias must be supported by evidence of actual bias or fundamentally unfair procedure; adverse outcomes and sharp disagreements with professional judgments are insufficient.
- Challenges framed as “due process” objections to a private accreditor are evaluated through this fairness-based, arbitrary-and-capricious/substantial-evidence framework rather than as direct constitutional due process claims against a state actor.

## Conclusion

The Fourth Circuit required deferential review of accreditor decisions, held ACCSC’s denial of PMTC’s reaccreditation was fair and supported by substantial evidence, rejected bias-based challenges, and reversed reinstatement and damages while affirming dismissal of PMTC’s state-law claims.


Prof'l Massage Training Ctr., Inc. v. Accred. All. of Career Schs. & Colls., 781 F.3d 161 (4th Cir. 2015)