## Facts

- The University of South Dakota adopted a rule requiring all single freshmen and sophomores to live in university residence halls unless the Director of Resident Services approved an exception before the semester.
- University officials stated the rule served financial and educational goals, including maintaining dorm occupancy to support repayment of revenue bonds and providing developmental and academic benefits associated with residence hall life.
- Gail Prostrollo and Lynn Severson, undergraduate students, challenged the rule on behalf of themselves and similarly situated students.
- The students alleged the requirement violated constitutional rights to privacy and equal protection.
- The district court found the rule’s primary purpose was generating dorm revenue for bond repayment and held the classification arbitrary and not rationally related to that purpose, enjoining enforcement.

## Issues

1. Whether requiring single freshmen and sophomores to live in university residence halls violates the Equal Protection Clause because the classification is arbitrary and not rationally related to legitimate state interests.
2. Whether the housing requirement unconstitutionally infringes a fundamental right of privacy or liberty in choosing where and with whom to live.

## Decision

- The Eighth Circuit reversed the district court and remanded with instructions to enter judgment for the defendants.
- The court applied rational basis review because the rule involved no suspect classification and did not burden a fundamental right.
- The court held the rule was rationally related to legitimate interests, including bond repayment and educational/developmental objectives for younger students.
- The court rejected limiting review to a single “primary” purpose, holding that any legitimate purpose supporting the classification suffices under rational basis review.
- The court held the rule did not violate a constitutionally protected privacy right and credited administrative judgment in residential and educational policy.

## Legal Principles

- If no fundamental right or suspect classification is implicated, a university regulation challenged under equal protection is upheld if it is rationally related to a legitimate governmental interest.
- Student class standing (freshman/sophomore) is not a suspect classification, and a preference to live off campus is not a fundamental constitutional right.
- Under rational basis review, a regulation may be sustained by multiple legitimate purposes; courts need not accept a trial court’s identification of a single dominant purpose.
- Courts generally defer to reasonable educational and administrative judgments in campus-life policy and will not invalidate such rules absent arbitrariness or caprice.
- A university residence requirement does not violate privacy where it does not substantially intrude on recognized fundamental privacy interests.

## Conclusion

The Eighth Circuit upheld the University of South Dakota’s requirement that single freshmen and sophomores live in university residence halls, concluding that the classification was rationally related to legitimate financial and educational objectives and did not infringe equal protection or a fundamental privacy right.


Prostrollo v. Univ. of S.D., 507 F.2d 775 (8th Cir. 1974)