Federal Court Dismisses Student Lawsuit Against Brown, URI and J&W Over Shifting to Online Learning

Federal Court Dismisses Student Lawsuit Against Brown, URI and J&W Over Shifting to Online Learning

A federal court in Rhode Island has dismissed a series of claims from students at the University of Rhode Island, Brown University, and Johnson & Wales who filed lawsuits alleging they were entitled to a tuition refund after the schools transitioned to remote learning due to COVID-19 for the remainder of the spring 2020 semester.

According to the court's decisions — the universities' refusal to refund tuition and other fees was the central dispute, “Plaintiffs contend that this denial amounted to a breach of express and implied contracts, and well as an unjust enrichment and conversion on the part of Brown.”

In response to Brown’s motion to dismiss for failure to state a claim, Judge John J. McConnell Jr. of the U.S. District Court in Rhode Island issued a March 4, 2021, court order that dismissed the breach of contract and tort claims in Choi et. al v. Brown related to payment of tuition.

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McConnell wrote, “Defendant universities are largely successful in their Motions to Dismiss Plaintiffs’ challenges to their decision to transition their programs online for the Spring 2020 term.”

He added, “Because plaintiffs failed to sufficiently allege breach of contract regarding tuition -- but did so regarding fees payments."

 

No Promise of In-Person Learning

In dismissing the tuition claims, McConnell wrote that “no plausible reading” of Brown’s course catalogs, student handbooks, policies, marketing or other materials offer a contractual promise for in-person education.

McConnell wrote that Brown University explicitly reserved the right to alter the administration of its academic offerings.

McConnell noted that the reality of the COVID-19 pandemic contrasted particularly with the plaintiffs’ claims that Brown’s “usual and customary practice of providing on-campus courses” contributed to an expectation that Brown would provide an on-campus educational experience.

“While this Court’s central finding is that nothing in the complaint indicates a contractual obligation for Brown to hold in-person programs, the unique nature of this moment warrants emphasis,” he wrote in his decision, which dismissed similar claims against three other Rhode Island universities as part of a consolidated order.

“Brown, and other Defendants were responding to the remarkable circumstances of this pandemic — which has upended countless aspects of our society’s usual and customary practices. One can reasonably infer that the universities reserved their rights for situations just like what occurred in 2020 — unexpected events, in this case a global pandemic.”

The case is a class action filed by the plaintiffs on behalf of students who paid Brown tuition, fees and/or room and board for the Spring 2020 semester. 

While Brown refunded unused room and board and recreation fees after transitioning to remote instruction, the court ruled that the plaintiffs alleged plausible claims that they expected certain services, such as student activities, in exchange for fees paid. This is the only issue left to be litigated, and the court established deadlines for discovery.