American Computer Institute, Inc. v. State of Alaska

995 P.2d 647 (2000)

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American Computer Institute, Inc. v. State of Alaska

Alaska Supreme Court
995 P.2d 647 (2000)

Facts

American Computer Institute, Inc. (ACI) (defendant) was a postsecondary institution that offered career-education programs to its students. ACI closed its campuses in Anchorage and Fairbanks, Alaska, mid-term without providing ACI students prior notice. For students in Fairbanks, ACI offered an accelerated “teach-out” program in which students could complete courses on an accelerated schedule. According to ACI, this accelerated program was allowed by the terms of ACI’s enrollment contract with students, which stated that ACI reserved the right to make changes to the program schedule. Each student enrolled at ACI signed an enrollment contract incorporating the school catalog by reference. ACI insisted that the teach-out program was substantially similar to the students’ original programming as described in the school catalog. For students in Anchorage, a separate institution, Charter College, offered ACI students one quarter of tuition-free coursework to allow students an opportunity to complete their programs. Charter College made this offer independently, without any arrangements from ACI. The coursework offered by Charter College was more rigorous and demanding than the coursework at ACI. Several students at Fairbanks refused to sign a contract to accept the teach-out program, and some students who began the teach-out program were unable to complete the program due to its fast pace. Similarly, some students at Anchorage failed to complete their programs at Charter College during the one free quarter or refused to enroll at Charter College. The State of Alaska (plaintiff) filed a lawsuit against ACI to require ACI to refund tuition to students who could not complete their programs of study due to the campus closures. The trial court found that ACI breached its enrollment contract by failing to provide the educational programming as required by ACI’s school catalog. The trial court ordered ACI to reimburse tuition to students who could not complete their programs due to the campus closures. ACI appealed.

Rule of Law

Issue

Holding and Reasoning (Fabe, J.)

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