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Anderson v. University of Wisconsin
United States Court of Appeals for the Seventh Circuit
841 F.2d 737 (1988)
Fradus Anderson (plaintiff) was an alcoholic who was admitted as a law student at the University of Wisconsin (law school) (defendant). Anderson did not meet the law school’s 77 grade point average (GPA) requirement during his first semester and failed to supply the law school with his undergraduate degree documentation. As a result, Anderson was not allowed to complete his second semester. The law school readmitted Anderson the next year despite his poor prior performance and new knowledge of his alcoholism. Anderson again performed poorly, earning a deficient grade in his legal-writing course and drunkenly threatening his legal-writing partner. Anderson asked to withdraw. The law school readmitted Anderson a third time, and again, Anderson failed to meet the minimum GPA requirement, warranting dismissal. Anderson applied a fourth time for readmission. The law school generally readmitted students whose academic difficulties stemmed from problems that had been overcome, predicting future success in the program. The law school retention committee (defendant) reviewed Anderson’s case three times, each time finding that because Anderson had not overcome his drinking problem, he was not prepared for the curriculum stress and would not be able to complete the program. Anderson issued a complaint to the university’s petitions committee (defendant), which reviewed his case and again found that, given his past academic record and his continued drinking, he was not eligible for readmission. The university’s vice chancellor (defendant) further reviewed the case and affirmed the decision. Anderson filed suit against the law school, both review committees, and the vice chancellor (school officials), claiming that denying his readmission violated the Rehabilitation Act. The district court granted summary judgment in favor of the school officials, and Anderson appealed to the Seventh Circuit.
Rule of Law
Holding and Reasoning (Easterbrook, J.)
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