Vought v. Teachers College, Columbia University

Michael Vought (plaintiff) applied to the Teachers College at Columbia University (Teachers College) (defendant). Having already accumulated 60 credits at Columbia University, Vought was interested in an accelerated program offered by the Teachers College, which would grant him a Bachelor of Science degree (B.S.) and a Master of Arts degree (M.A.) after two more years of study, saving him one full year of study. Vought received an advisory statement from Teachers College referring to the possibility of granting him both a B.S. and M.A., and subsequently a letter from Teachers College stating that his application for the combined-degree program was pending approval. Vought’s letter of acceptance from the Teachers College noted that his admission would lead to an M.A. However, Vought was told that his application for the combined program was still pending. After six months, Vought was informed that his application for the combined program would not be approved in time. Vought continued his undergraduate studies at Columbia University and, despite not being able to enroll in the combined program, obtained an M.A. the traditional way, as a separate degree program. Vought filed suit against Teachers College for breach of contract, fraud, and negligence. A lower court granted Teachers College’s motion for summary judgment, rejecting Vought’s argument that Teachers College promised him a combined degree and relying in part on Vought’s own testimony as to his awareness that his application for the combined program was never officially approved. Vought appealed.