Board of Curators of the University of Missouri v. Horowitz

United States Supreme Court435 U.S. 78 (1978)

Facts

The University of Missouri-Kansas City Medical School (defendant) dismissed Ms. Horowitz (plaintiff) during her final year of study based on her failure to meet academic standards. Prior to her dismissal, Horowitz received low ratings for her clinical performance and was advanced to her final year only on a probationary basis. The faculty routinely expressed its dissatisfaction with Horowitz’s clinical skills and behavior. Based on these expressions of dissatisfaction and other critical evaluations, the Council of Evaluation (Council) recommended that she not be permitted to graduate, and that she be dismissed unless her performance improved. Seven practicing physicians and additional faculty then reviewed Horowitz. Based on the negative nature of these evaluations, the Council recommended her dismissal. Horowitz appealed in writing to the University’s Provost for Health Sciences. Upon reading the record of earlier proceedings, the Provost sustained the school’s actions. Horowitz sued the school under 42 U.S.C. § 1983, arguing that she was not accorded procedural due process prior to dismissal. The district court dismissed Horowitz’s complaint which was reversed on appeal by a divided court. The United States Supreme Court granted certiorari.

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