Summary
The Fifth Circuit affirmed the dismissal under Federal Rule of Civil Procedure 12(b)(6) of Daniel Hux’s claim that Southern Methodist University breached a tort duty of good faith and fair dealing. Applying Texas law, the court held that Texas does not impose such a duty in the student-university relationship and that Hux’s allegations did not establish a qualifying special relationship.
Topics
Practice areas
Questions Presented
- Whether Texas law recognizes a tort duty of good faith and fair dealing in the student-university relationship.
- Whether Hux alleged facts sufficient to establish a special or confidential relationship that could give rise to such a duty.
Holdings
- Texas law does not impose a tort duty of good faith and fair dealing in an ordinary student-university relationship.
- Hux did not plead facts establishing a special or confidential relationship with SMU administrators sufficient to support a duty of good faith and fair dealing.
Key quotations
“Because Texas law does not impose a duty of good faith and fair dealing in the student-university relationship, we affirm.” (slip op. at 1)
“Hux’s appeal fails for at least two independent reasons.” (slip op. at 9)
Factual background
Daniel Hux was an undergraduate student and community advisor at Southern Methodist University during the 2010–2011 academic year. After university staff raised concerns about his interactions with staff members and another student, SMU terminated him from his community-advisor position, denied his appeal, restricted his campus access, and later placed him on mandatory administrative withdrawal. Hux alleged that SMU administrators' counseling, mental-health referrals, and expressions of concern created a special relationship giving rise to a tort duty of good faith and fair dealing.
Procedural history
Hux filed suit asserting approximately nineteen causes of action against SMU and related defendants. The district court dismissed most claims under Rule 12(b)(6) and granted summary judgment on the remaining claims. The claim at issue on appeal was dismissed before discovery for failure to state a claim.