Johnson v. Lincoln Christian College

In 1981 Gregory Johnson (plaintiff) completed a five-year program at Lincoln Christian College (Lincoln) (defendant), but Lincoln refused to provide him with a diploma, citing rumors that he was homosexual. Lincoln informed Johnson that he would only receive a diploma after completing counseling with a therapist. During the counseling sessions, Johnson, who was under the impression that the conversations were confidential, revealed personal information about himself. Although Johnson never consented to the disclosure, much of this information was communicated to Lincoln. After being informed by the therapist that Johnson was not experiencing any significant change, Lincoln informed Johnson that it would hold a hearing, at which he would be required to defend himself. Johnson declined to take part and withdrew from the university. In 1984, amid Lincoln’s continued refusal to grant him a degree, Johnson filed suit, bringing numerous claims against Lincoln, including breach of his contract and violation of the Mental Health and Developmental Disabilities Confidentiality Act (the act), which prevented disclosure of disabilities without consent. The circuit court granted Lincoln’s motion to dismiss, and Johnson appealed. With respect to his breach-of-contract claim, Johnson argued that his contract as a student was implied by law, that it contained an implied promise by Lincoln not to arbitrarily or maliciously prevent a student from graduating, and that Lincoln breached its contract by failing to grant him a diploma. Lincoln argued that Johnson could not establish the terms of the contract, because he did not submit anything into evidence to do so.