Haberle v. University of Alabama in Birmingham

803 F.2d 1536 (1986)

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Haberle v. University of Alabama in Birmingham

United States Court of Appeals for the Eleventh Circuit
803 F.2d 1536 (1986)

Facts

Frederick Haberle (plaintiff) was a graduate student at the University of Alabama at Birmingham (UAB) (defendant) seeking a Ph.D. in chemistry. When Haberle entered the chemistry program, he received a document titled “Requirements for Degree in Chemistry,” which listed the requirements for a Ph.D. in chemistry as completion of course work, competency in two foreign languages, a passing grade on the qualifying examination, presentation at two seminars, and completion of a dissertation. Haberle completed all required coursework, demonstrated his competency in two foreign languages, and presented at one seminar. Haberle began his dissertation research in 1981. At that time, the graduate committee supervising Haberle met to discuss Haberle’s progress. The committee noted that Haberle had not taken the qualifying examination, but no date for the examination was set. Haberle continued his dissertation research through 1984. At that time, the graduate committee met and notified Haberle that he must still take the qualifying examination, even though the exam should have been taken before beginning his dissertation research. No student had ever been awarded a Ph.D. in chemistry from UAB without passing the qualifying examination. Haberle failed the qualifying exam twice and was dismissed from the Ph.D. program. Haberle filed a grievance, which was denied. Haberle then filed a lawsuit against UAB, arguing that Haberle’s dismissal from the program was arbitrary and that his procedural and substantive due-process rights were violated. The district court granted summary judgment in favor of UAB. Haberle appealed.

Rule of Law

Issue

Holding and Reasoning (Hill, J.)

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