Summary
The Seventh Circuit affirmed summary judgment for Rose-Hulman Institute of Technology on a student's ADA Title III failure-to-accommodate claim, holding that claims based on events before March 2015 were time-barred by Indiana's two-year personal injury statute of limitations and that the student failed to show any link between his disability and the academic misconduct leading to his suspension and denial of readmission. The court also affirmed summary judgment on breach of contract claims, applying Indiana's deferential standard that courts will not interfere with a university's academic judgment absent a showing of bad faith or arbitrary/capricious action, and on defamation claims where the professor's letter of academic misconduct was protected by qualified privilege. The district court's sanctions for failure to comply with a scheduling order were affirmed as within its discretion.
Topics
Practice areas
Questions Presented
- Whether the district court erred in granting summary judgment on Castelino's ADA claim for failure to accommodate.
- Whether the district court erred in granting summary judgment on Castelino's breach of contract claim.
- Whether the district court erred in granting summary judgment on Castelino's defamation, harassment, and false advertising claims.
- Whether the district court abused its discretion in imposing sanctions for failure to comply with a scheduling order.
Holdings
- Summary judgment was proper because Castelino failed to show that Rose-Hulman failed to accommodate his disability or discriminated against him; the incidents of misconduct were not linked to his disability.
- Even assuming an implied contract, deviations from university procedures were not arbitrary, capricious, or in bad faith, so no breach occurred.
- The defamation claim was properly dismissed because Dr. Chapman's letter was protected by qualified privilege and Castelino failed to show abuse of that privilege.
- No abuse of discretion because Castelino's counsel failed to comply with the scheduling order by serving the settlement demand late.
Key quotations
“Castelino fails to identify any facts in the record establishing that Rose-Hulman or any of its professors failed to accommodate his learning disability. Instead, the undisputed facts establish that he was suspended and then ultimately denied readmission based on several instances of academic misconduct and other behavioral issues that have no link to his learning disabilities or need for accommodations from Rose-Hulman.” (at 14)
“At best, Castelino provided evidence of inconsequential deviations from various procedures in the Student and Faculty Handbooks. He has failed to identify any facts in the record that could plausibly lead to the conclusion that Rose-Hulman undertook 'the conscious doing of a wrong because of dishonest purpose or moral obliquity' or had 'a state of mind affirmatively operating with furtive design or ill will.'” (at 20)
Factual background
Castelino, a student with ADHD and a learning disorder, received accommodations from Rose-Hulman including extended test time. He was disciplined for academic misconduct on three occasions, the last involving using cut-and-pasted course slides on a typed notecard in violation of a professor's policy. He was suspended for one quarter and later denied readmission after multiple applications. He sued, alleging disability discrimination under the ADA, breach of contract, defamation, and other claims.
Procedural history
The district court entered summary judgment for Rose-Hulman on all counts and granted Rose-Hulman's motion for sanctions. Castelino appeals.