Halasz v. University of New England

The University of New England (university) (defendant) was a private college with a competitive admissions process based on applicants’ academic records, recommendations, and standardized college aptitude tests. Transfer students with a grade point average (GPA) of 2.5 or higher were considered for admission, and the university rarely accepted any transfer students with a GPA below 2.0. Learning-disabled students who qualified for admission could join the Individual Learning Program (ILP), which offered extra support services including taped textbooks, readers, untimed exams, and individualized counseling. Learning-disabled students who did not meet admissions requirements could join the First Year Option (FYO) program. FYO students took a few degree courses per semester as nonmatriculated students, received the support services of the ILP, and then applied for regular admission to the university based on their performance. Only FYO students holding a 2.0 GPA for two semesters qualified for regular admission. Ronald Halasz (plaintiff) had a learning disability and Tourette’s syndrome and applied for transfer admission. Halasz had dropped out of three prior colleges, including one with a specialized disability program, and had a 1.98 GPA. Halasz scored the lowest possible score on his untimed reading aptitude tests and had very low standard aptitude test (SAT) scores. The university had never accepted an applicant with scores as low as Halasz’s. Halasz inquired about the disability programs and wrote a letter stating that his record did not show his actual abilities. The university denied Halasz regular admission but admitted him to the FYO program. Halasz performed poorly despite receiving copious support services, tutoring sessions, and counseling, earning a cumulative GPA of 1.375. Based on his program performance, the university again denied Halasz regular admission. Halasz filed suit in federal district court, claiming that the university discriminated against him twice by denying him regular admission in violation of the Rehabilitation Act. Halasz also claimed that the university improperly inquired about his disability status during the preadmission process. The court found that the university was allowed to ask for information on Halasz’s disabilities in response to his own inquiries regarding the learning-disabled programs and to evaluate whether the programs would benefit Halasz. The court then addressed the discrimination claims.