Professional Massage Training Center, Inc. v. Accreditation Alliance of Career Schools and Colleges

The Professional Massage Training Center (PMTC) (plaintiff) was a single-discipline massage-therapy training school in Springfield, Missouri. The Accreditation Alliance of Career Schools and Colleges (ACCSC) (defendant) was a non-profit corporation that accredits private schools of higher education offering career-oriented programs. ACCSC established standards of accreditation that established the criteria schools must meet to obtain and maintain accreditation. Accreditation from ACCSC is necessary to receive Title VI federal student-aid funding. ACCSC determined that PMTC had many issues when PMTC applied for a renewal of its accreditation. These issues included problems with management capability and retention of administrative staff, failures in strategic planning, lack of professional development, failure to demonstrate adequate student achievement and employment rates, and deficiencies in the processes for verification of faculty credentials. Therefore, ACCSC denied the application for renewal of PMTC’s accreditation. PMTC appealed the decision to an independent appeals panel, which affirmed the denial. PMTC then sued ACCSC under various common-law theories for denying the application. The trial court determined that ACCSC violated PMTC’s due-process rights and awarded $429,016.62 in damages. ACCSC appealed to the United States Court of Appeals for the Fourth Circuit.