Falcone v. University of Minnesota

Christopher Falcone (plaintiff) was a student at the University of Minnesota Medical School (school) (defendant) and lived with learning disabilities. During the first half of his medical education, Falcone took classroom courses and received repeated accommodations to pass the courses after failing several of them. Falcone then began the second half of his medical education, which involved clinical rotations. Falcone failed a clinical rotation and received additional accommodations to retake the rotation and complete other necessary rotations. The accommodations included additional time and breaks and weekly feedback meetings with instructors. Even so, Falcone failed two more clinical rotations. The school’s academic committee decided to dismiss Falcone from the school. The committee gave two reasons: (1) Falcone had received reasonable accommodations and (2) Falcone still failed to perform clinical reasoning in a clinical setting, which was necessary to becoming a physician. Falcone sued the school, claiming it had violated § 504 of the Rehabilitation Act. The district court granted the school’s motion for summary judgment, concluding that Falcone was not qualified for the program and that even assuming he was qualified, Falcone was not dismissed solely because of his disability. On appeal, Falcone argued that the school dismissed him in bad faith, which established that he was dismissed solely because of his disability. Falcone also argued that he would have been qualified had the school properly implemented the feedback accommodation.