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MacDonald v. Thomas M. Cooley Law School
United States Court of Appeals for the Sixth Circuit
724 F.3d 654 (2013)
The Thomas M. Cooley Law School (Cooley) (defendant) was an American Bar Association-accredited law school in Michigan. Cooley had the lowest admissions standards of any accredited law school in the country, and a significant percentage of students who entered law school at Cooley failed to graduate. Cooley published an annual employment report that included self-reported information provided by some of its graduates. The employment reports contained the percentage of Cooley graduates who were employed within nine months of graduation. The employment reports did not specify that the statistics reflected full-time employment that required or preferred a law degree. The 2010 employment report, for example, stated that 76 percent of Cooley graduates were employed within nine months of graduating and that the average starting salary of all graduates was $54,796, but the report did not state that the employment was specifically in the legal field. A group of 12 Cooley graduates (the plaintiff graduates) (plaintiffs) filed a lawsuit against Cooley in federal district court, claiming that Cooley committed fraudulent misrepresentation by publishing false postgraduation employment statistics. The plaintiff graduates argued that the employment reports misleadingly included statistics about any type of employment, rather than full-time employment that required or preferred a law degree. Cooley filed a motion to dismiss the complaint. The district court granted Cooley’s motion to dismiss, holding that the plaintiff graduates could not have reasonably relied on the employment reports. The plaintiff graduates appealed.
Rule of Law
Holding and Reasoning (Martin, J.)
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