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Rodi v. Southern New England School of Law

United States Court of Appeals for the First Circuit
389 F.3d 5 (2004)


Facts

Joseph Rodi (plaintiff) received a recruitment letter from the Southern New England School of Law (SNESL) (defendant) stating that SNESL was highly confident the school would receive accreditation from the American Bar Association (ABA). The letter also stated that the future of the school had never been brighter. Rodi enrolled at SNESL and received a catalogue from the school. The catalogue contained a statement that SNESL was not representing that the school would be accredited by the ABA prior to the graduation of any student. During Rodi’s first year, the ABA denied SNESL’s application for accreditation. Rodi considered transferring to another law school, but the acting dean wrote a letter to Rodi, stating that SNESL was improving the areas found to be deficient by the ABA and that there was no cause for pessimism. Rodi remained at SNESL, but the ABA denied SNESL’s renewed application for accreditation during Rodi’s third year of law school. As a result, Rodi was not permitted to take the New Jersey bar exam. Rodi sued SNESL for fraudulent misrepresentation. Rodi alleged SNESL knew that the ABA was highly critical of SNESL and that accreditation was very unlikely. SNESL moved to dismiss the lawsuit. The district court granted the motion to dismiss, and Rodi appealed to the United States Court of Appeals for the First Circuit.

Rule of Law

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Issue

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Holding and Reasoning (Selya, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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