Doe v. New York University

Jane Doe (plaintiff) suffered from psychiatric and mental disorders, including borderline personality disorder, which caused self-destructive, self-harming, and antisocial behavior from age 14 into adulthood. Doe falsely represented her mental-health history in her application to medical school at New York University (university) (defendant), stating that she had no mental-health concerns or conditions. After Doe was admitted, the university learned about her history and conditions during a mandatory medical exam performed in preparation for part of the program. Doe agreed to begin psychotherapy but failed to follow through, and the university and Doe agreed that she would take a leave of absence, after which Doe could request reinstatement into the program. Doe eventually applied for readmission and submitted letters of support from her psychiatrists stating that she met the university’s reinstatement standards of (1) being able to handle medical-school stresses, (2) functioning properly after graduation, and (3) posing no significant risk of reexhibiting prior behaviors. The university denied Doe’s application due to her risk of relapsing and the potential danger Doe posed to herself, her peers, and her potential patients. Doe filed suit in federal district court, claiming that by denying her readmission, the university discriminated against her in violation of the Rehabilitation Act. The university moved for summary judgment, putting forward expert testimony that Doe had a possibility of relapsing and posed a safety risk to herself and those involved in the program. The district court denied the university’s motion and issued a preliminary injunction to force the university to readmit Doe as a medical student. The university appealed to the Second Circuit. The appellate court found that Doe failed to show a risk of irreparable injury as required for preliminary-injunctive relief and reversed the preliminary injunction. The court then addressed the denial of the university’s motion for summary judgment.