## Facts

- Teachers College advertised an “Accel‑A‑Year” accelerated program described as leading to a combined B.S./M.A. degree, subject to additional study.
- Michael Vought, who had completed 60 undergraduate credits at Columbia, applied to Teachers College after seeing the advertisement and expressed interest in the combined program.
- Teachers College provided an advisory statement indicating that approval for the combined B.S./M.A. program was pending with state authorities (“application is in process … for approval”).
- Vought’s application selected “Master of Arts Degree,” and the acceptance letter referred to admission to a program leading to an M.A. degree.
- During an interview, a college representative stated the program would lead to an M.A. and that the combined-degree program had been applied for but was not yet approved.
- After about six months, Teachers College informed Vought that approval would not be obtained in time for him to receive a combined degree and suggested returning to his undergraduate studies.
- Vought returned to undergraduate studies and later received an M.A. through the traditional route (awarded October 1982).
- Vought sued for breach of contract, fraud, and negligence, claiming he was promised a combined B.S./M.A. and suffered damages from relying on that promise.

## Issues

1. Whether the parties’ student–university relationship and related materials created an enforceable contract obligating Teachers College to confer a combined B.S./M.A. degree notwithstanding express statements that program approval was pending.
2. Whether statements about the combined-degree program amounted to an actionable misrepresentation of existing fact supporting a fraud claim.
3. Whether Teachers College owed and breached an independent duty in negligence based on its communications and handling of the program approval process.

## Decision

- The Appellate Division affirmed summary judgment dismissing the complaint.
- No enforceable promise of a combined B.S./M.A. was shown because the record made clear the combined program was contingent on external approval.
- Teachers College satisfied any contractual obligation by admitting Vought to, and ultimately conferring, the M.A. degree he applied for and was accepted into.
- The fraud claim failed because the statements concerned a pending approval process and did not establish a misrepresentation of present fact.
- The negligence claim failed because the alleged wrongdoing did not establish a separate tort duty or triable issue distinct from the contractual dispute.

## Legal Principles

- Admission to a university creates an implied contract that the student will receive the degree sought if the student complies with the institution’s prescribed requirements.
- The terms of the implied student–university contract are derived from the institution’s written materials (e.g., bulletins, circulars, regulations) made available to the student.
- Conditional statements about future events dependent on regulatory approval do not constitute an unconditional contractual commitment to deliver that future benefit.
- Fraud requires a material misrepresentation of an existing fact, reasonable reliance, and damages; unmet expectations about future contingencies generally do not suffice.
- Where the dispute is fundamentally contractual, an alleged failure to achieve a hoped-for academic outcome does not, without independent wrongful conduct, create a viable negligence claim.

## Conclusion

The court held that Teachers College did not breach any implied contract or commit fraud or negligence because the combined-degree program was expressly subject to state approval, while Vought applied for, was accepted into, and ultimately received an M.A., satisfying the institution’s obligation under the operative admissions documents and published terms.


Vought v. Teachers Coll., Columbia Univ., 127 A.D.2d 654, 511 N.Y.S.2d 880 (2d Dep’t 1987)