## Facts

- Two Kent State alumni received bachelor’s degrees and, more than ten years later, the university concluded their records showed they had not satisfied substantive degree requirements.
- The university initiated internal degree-revocation proceedings and notified the alumni in writing.
- Kent State provided access to documents it intended to use, advance notice of a hearing before a university committee, and an opportunity to confront witnesses and present evidence.
- The alumni challenged the process, including limits on attorney participation, and argued the university lacked authority to revoke degrees after conferral.

## Issues

1. Whether a public university’s board of trustees has inherent or implied authority to revoke an academic degree that was improperly awarded.
2. Whether degree revocation, if authorized, must be conditioned on good cause and constitutionally adequate procedures.

## Decision

- The Supreme Court of Ohio reversed the appellate judgment that had barred revocation for lack of statutory authority.
- The court held that university boards have inherent authority to revoke previously granted degrees for proper cause after providing constitutionally adequate procedures.
- The court confined its review to the authority question and did not resolve broader procedural disputes beyond noting the procedural record and the limited counsel-related claim.

## Legal Principles

- A university’s express statutory authority to confer academic degrees implies authority to revoke degrees erroneously or improperly granted when reasonably related to the institution’s duties.
- Degree revocation is permissible where: (1) good cause (e.g., fraud, deceit, or error) is shown, and (2) the degree holder receives a fair hearing with an opportunity to present evidence and protect the asserted interest.
- Universities have a legitimate institutional interest in the integrity of their degrees, which function as a certification to the public of the recipient’s fulfillment of academic standards.

## Conclusion

The court recognized an implied and inherent power in public university trustees to rescind degrees that were improperly awarded, conditioned on a showing of good cause and the provision of fair, constitutionally adequate process to the degree holder.


Waliga v. Bd. of Trs. of Kent State Univ., 488 N.E.2d 850 (Ohio 1986)