Abrams v. Illinois College of Podiatric Medicine

Jonathan Abrams (plaintiff) was a student at the Illinois College of Podiatric Medicine (College) (defendant) for one year. During his first semester at the College, Abrams failed Physiology 101. The College allowed him to retake the exam, but Abrams failed again. The College then removed Physiology 203 from Abrams’s second-semester schedule, telling Abrams that, if he passed all the classes in his reduced workload, Abrams could retake Physiology 101 in the summer. Throughout the year, Abrams talked with College representatives about his struggle to keep up with the customary workload. The College reassured Abrams that the College would make an effort to help Abrams through. The student handbook said that it was “desirable” for professors to keep their students up-to-date about their progress. The handbook also said that students “should be” told how they were doing shortly after mid-terms and given recommendations to help them improve. Abrams’s professors, however, did not update him about his progress or standing throughout the school year. Ultimately, Abrams failed two of his second-semester courses and the College expelled him. Abrams then sued the College for breach of contract, arguing that the handbook’s language and the College representatives’ statements to him created a binding contract. The trial court ruled in favor of the College. Abrams appealed.