Philip Crosby Associates v. Florida State Board of Independent Colleges

506 So. 2d 490 (1987)

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Philip Crosby Associates v. Florida State Board of Independent Colleges

Florida District Court of Appeal
506 So. 2d 490 (1987)

Facts

Philip Crosby Associates (Crosby) (defendant) ran a management-consulting firm to help clients improve their services. A division of the company, Quality College, held seminars in various classrooms throughout Florida on the quality-improvement process. Crosby did not offer any college credit or academic degrees beyond the secondary level. The Florida State Board of Independent Colleges (the board) (plaintiff) notified Crosby that state law did not allow any entity in Florida to use the words college or university without approval from the board. At a subsequent meeting, the board determined that Crosby and its Quality College did not require licensure by the board, because it did not offer college degrees. After Crosby filed a formal petition for a declaratory statement and a hearing was held, the board issued a final order, reaffirming that Crosby did not require licensure but preventing Crosby from using the word college with respect to any activities conducted by Quality College. The board cited Florida Statute § 246.121, which reserved use of the terms college and university to institutions that granted degrees and were licensed by the board. Crosby filed an appeal.

Rule of Law

Issue

Holding and Reasoning (Johnson, J.)

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