Arizona Board of Regents v. Wilson

Rubye Wilson (plaintiff) submitted an application for the fine-arts program at Arizona University’s College of Fine Arts. Wilson’s application was denied by the head of the art department. Wilson’s application, which included samples of her work, was reviewed by a faculty committee, which ultimately determined that her work, although on a professional level, was not “harmonious with the esthetic attitudes within the art department.” The faculty committee’s review process did not involve any checklist or set of objective criteria. Rather, each member of the committee evaluated the candidate’s work and decided whether the candidate had the potential to succeed as an artist in the program. Additionally, applications were approved on a rolling basis, resulting in a higher approval rate for applications submitted earlier in the process. Wilson’s application was considered on the last day, and out of 14 applications reviewed on that day, only two were selected. Wilson filed suit against Arizona’s Board of Regents (the board) (defendant), arguing that her rejection was arbitrary, capricious, and unreasonable, citing her successful academic record in undergraduate studies and her own résumé, which included several awards and purchases of her work. At trial, several members of the committee, as well as Wilson’s previous teachers, testified. Members of the admissions committee explained their criticisms and concerns with Wilson’s work, and her former teachers testified as to difficulties they experienced while working with her. A trial court ruled in Wilson’s favor and granted her an order requiring Arizona to admit her, finding that the art department’s reasoning was an insufficient basis for its decision and noting the lack of objective criteria used in the process. The board appealed.