Crook v. Baker

Wilson Crook (plaintiff) received a master of science degree in geology and mineralogy from the University of Michigan (Michigan) (defendant). Crook’s thesis was based on a claim that he had discovered a previously unknown mineral, “texasite,” while on a field trip. The claims made by Crook were supported by data he submitted with his thesis, which were compiled using a microprobe and a computer program at Michigan, EMPADR, that was available to students and researchers. A year after Crook was awarded his degree, professors in the Geology and Mineralogy Department determined that Crook had likely fabricated his data and that texasite was not actually a newly discovered mineral. The professors based this on time-log records of EMPADR and their general belief that the data was too good to be true. Moreover, the chemical composition of texasite was very similar to a synthetic compound that had been produced in a Michigan lab. Crook denied any wrongdoing. When Crook attempted to replicate the results, it was discovered that he manipulated the data. In a letter to Crook, Michigan charged him with fabricating the data in his thesis, based on the analytical results, EMPADR’s time log, and the discovery that texasite was a synthetic compound. Crook was informed that a disciplinary committee would hear the matter and that his degree might be revoked. Crook had assistance from an attorney through the whole process. The hearing was informal. Crook presented evidence and witnesses. Although neither side was permitted to directly cross-examine witnesses, Crook himself was able to ask questions to witnesses. Both Crook and his attorney made statements to the committee during the hearing. Ultimately, the committee determined that Crook had lied about his data, and the board of regents (the board) voted to rescind his degree following a meeting at which Crook’s attorney argued on his behalf. Crook refused to give up, convincing a district court that he had been denied due process. Michigan appealed.