Board of Curators of the University of Missouri v. Horowitz (1977)
- Docket
- 76-695
- Decided
- 1977-01-01
Summary
Question: Does an academic dismissal from a university without a hearing before the school’s decision-making body violate the Due Process Clause of the Fourteenth Amendment? Conclusion: No. Justice William H. Rehnquist delivered the opinion of the 6-3 majority. The court held that the procedures leading to the Horowitz’s dismissal for academic deficiencies did not violate the Due Process Clause of the Fourteenth Amendment. Horowitz was fully informed of the faculty dissatisfaction with her clinical progress and the threat of postponing her graduation and continued enrollment. The Court held that a hearing before the school’s decision-making body is not required for dismissals for academic deficiencies. Justice Lewis F. Powell, Jr. wrote a concurring opinion in which he added that Horowitz was dismissed for academic deficiencies rather than for disciplinary reasons, and that in these circumstances she was accorded due process. Justice Thurgood Marshall wrote an opinion concurring in part and dissenting in part in which he argued that the various meetings about Horowitz’s academic performance met the standards of procedural due process. However, the procedure of dismissal for academic reasons, rather than disciplinary reasons was arbitrary. In his separate opinion concurring in part and dissenting in part, Justice Harry A. Blackmun, with whom Justice William J. Brennan, Jr. joined, wrote that Horowitz received the procedural process due under the Fourteenth Amendment, but that the Court should not decide what the further appropriate procedures are required in graduate school dismissals.