Quinnipiac University (University) is a private university located in Connecticut. During the spring 2020 semester, the University transitioned to online learning in response to the COVID-19 pandemic. The University provided housing and dining credits for the spring 2020 semester but did not provide tuition or fee refunds.
Thereafter, two students who were enrolled in the University at the time of the transition and two parents who each had a child who was enrolled in the University at the time of the transition, filed a lawsuit against the University for breach of contract, breach of implied contract, unjust enrichment, and conversion. The students and parents alleged that the online classes that the University provided were not equivalent to the in-person, on-campus education that they enrolled in and paid for and the students were deprived of hands-on educational opportunities and experiences.
The students and parents also alleged that it was difficult to access and communicate with professors during online learning and many professors were unprepared to deliver an effective educational experience using online learning technologies. The students and parents cited language in University educational, promotional, and registration materials highlighting the on-campus experience, which they asserted led to their reasonable expectation when registering for classes for the spring 2020 semester that those classes would be provided on-campus. They also allege that the language in University educational, promotional, and registration materials contractually obligated the University to deliver in-person instruction. Interestingly, the students and parents noted that before the transition, the University charged between $515 and $575 per credit for undergraduate online degree programs, and between $1,517.50 and $2,023.33 per credit for on-campus courses, which they say demonstrate the significant difference between the values of online and in-person education. The University filed a motion to dismiss.
The court first analyzed whether the parents had the standing to bring their claims against the University. To have standing, the parents were required to show (1) an injury in fact; (2) a sufficient causal connection between the injury and the conduct complained of; and (3) a likelihood that the injury will be redressed by a favorable decision. Alternatively, the parents could establish standing by showing (1) the existence of a valid contract; (2) the parents’ performance or excuse for nonperformance; (3) the University’s breach of contract; and (4) resulting damages.
The court held that the parents did not have to stand under either method. The court noted that the fact that a parent pays tuition on behalf of his or her adult child does not confer standing on that parent to sue for breach of an obligation that the college or university owed the child. The court further noted that the parents did not have a contract with the University; the contract at issue was between the adult students and the University, and the parents’ financial loss derives from a private arrangement between the parents and their children. If, however, the parents had a valid contract with the University and had alleged an injury arising from a breach of that contract, the court explained that the parents may have been able to assert a contractual standing to bring the suit. Therefore, the court dismissed the parents’ breach of contract, breach of implied contract, and unjust enrichment claims.
The court next analyzed whether the students’ claims were barred by the educational malpractice doctrine. The educational malpractice doctrine bars the court’s interference in any complaint that essentially alleges that an educational institution breached its agreement by failing to provide effective education and would require the court to evaluate the course of instruction and method of teaching that has been adopted by that educational institution. The court expressed its belief that the students’ claim could be resolved without implicating the educational malpractice doctrine. The court noted that if it later becomes clear that the court cannot resolve the students’ claims without evaluating whether a course conducted remotely was less valuable than one conducted in person, and if so, by how much, the court will reassess whether this matter is barred by the educational malpractice doctrine.
The court then analyzed the students’ contract-related claims. The court allowed the students’ breach of contract claim to proceed. The court determined that the students produced sufficient evidence to allow for the inference that the University’s course and registration materials contained a specific promise to provide in-person instruction. The court also allowed the students’ unjust enrichment claim to proceed because the students produced sufficient evidence that the University may have accrued excess funds by transitioning to remote learning. Finally, the court dismissed the students’ conversion claim, finding that the students’ had relinquished the tuition funds and other fees to the University and those amounts no longer belonged to the students.
Metzner v. Quinnipiac University (D. Conn., Mar. 25, 2021, No. 3:20-CV-00784 (KAD)) 2021 WL 1146922.
NOTE:
In December 2020, a California court addressed a similar issue in Steven J. Lindner v. Occidental College. For more information, see the LCW article titled, Student’s Suit For Partial Tuition Refund Due To Transition To Virtual Instruction Fails.