Mangla v. Brown University

• Decision Date: 28 July 1997
• Docket Number: No. 96-2333,96-2333
• Parties: 123 Ed. Law Rep. 538 Gaurav MANGLA, Plaintiff-Appellant, v. BROWN UNIVERSITY, Defendant-Appellee. . Heard
• Court: U.S. Court of Appeals — First Circuit

Page 80

135 F.3d 80

123 Ed. Law Rep. 538

Gaurav MANGLA, Plaintiff-Appellant, v. BROWN UNIVERSITY, Defendant-Appellee.

No. 96-2333.

United States Court of Appeals, First Circuit.

Heard July 28, 1997.

Decided Feb. 2, 1998.

Douglas A. Giron, Providence, RI, for appellant.

Christopher H. Little, with whom John E. Bulman and Little Bulman & Reardon, P.C., Providence, RI, were on brief, for appellee.

Before BOUDIN, Circuit Judge, JOHN R. GIBSON, ^* Senior Circuit Judge, and POLLAK, ^** Senior District Judge.

JOHN R. GIBSON, Senior Circuit Judge.

Gaurav Mangla appeals from a judgment as a matter of law entered in favor of Brown University following a trial on his breach of contract and promissory estoppel claims. He argues that the district court erred in granting judgment, as a reasonable jury could have found that Brown breached the contract, acted arbitrarily and in bad faith, and that Brown was estopped from denying him admission to the graduate school. He argues that the court improperly raised certain evidence and overlooked and misconstrued other evidence in reaching this decision. We affirm the judgment of the district court.

Mangla applied for admission to the Brown Graduate School in September 1993, and was admitted as a probationary special student, a category of enrollment that permits the taking of graduate level courses but which is not in itself a degree program. His admission in this capacity was recommended by the Computer Science Department and approved by the graduate council. Associate Dean Joan Lusk met with Mangla at that time and explained to him that his admission was probationary because he lacked the requisite academic background or course work in computer science. Lusk further told Mangla that in order to be admitted to the degree program he would need to successfully complete course work in the Computer Science Department. Mangla claims to have satisfactorily completed seven of the eight courses required for a Master's degree.

After completing such course work, Mangla inquired of Dean Lusk about his probationary status, and she instructed him to obtain a faculty advisor for his Master's Project. In response, Mangla obtained a letter signed by Professor Stanley Zdonik, stating that Mangla "will be working under my supervision for his Master's project." Mangla claims that at the time he believed the letter served as a letter of recommendation for admission into the degree program.

In September 1995, Brown informed Mangla that his special student status was discontinued and that he had not been admitted into the Master's program. Mangla thereafter filed a new, formal application for admission into the Master's program. The Computer Science Department faculty reviewed the new application and voted to recommend that Mangla's application be denied. Mangla then appealed to the Graduate Council which voted unanimously to uphold the department's decision.

Mangla brought this action for breach of contract and promissory estoppel for Brown's refusal to admit him into its Master's program. The action was tried before a jury, but at the close of evidence, the judge granted judgment as a matter of law to Brown and dictated detailed findings into the record. The district court first decided that there was no breach of contract because Mangla knew that one of the things he had to do in performing his side of the contract was to obtain a favorable recommendation from the Computer Science Department faculty and there was no evidence that any such recommendation was obtained. The court acknowledged Mangla's testimony that Dean Lusk told him he would absolutely be admitted if he passed his courses or if he got a faculty member to act as his advisor. The court stated, however, that the key testimony was Mangla's admissions that notwithstanding anything that Dean Lusk may have told him, he knew that a recommendation from the faculty was a requirement for his admission into the Master's Program.

The court further found that there was no promissory estoppel because there was no reasonable reliance on any of the alleged representations. There was explicit language in the Graduate School manual that even the department does not have the power to offer admission and that offers of admission have binding force only when made by the Graduate School in writing. The court stated that Mangla's argument that he was entitled to the written offer of admission is nothing more than a circumvention of the explicit requirement set forth in the Graduate School manual. Further, the district court stated that it was quite a stretch to interpret Professor Zdonik's letter as amounting to a recommendation by the Department that Mangla be accepted. Even viewing the letter in the light most favorable to Mangla, the district court determined that it defied logic and reason to read the letter as a recommendation from the Computer Science Department. Thus, the district court held that there was no issue for the jury to decide, and judgment as a matter of law was granted.

I.

In ruling on a motion for judgment as a matter of law, the district court must examine the evidence, and inferences to be drawn therefrom, in the light most favorable to the non-movant. See Roln-Alvarado v. Municipality of San Juan, 1 F.3d 74, 76 (1st Cir.1993). Judgment as a matter of law may then be granted "only if the evidence, viewed from this perspective, is such that reasonable minds could not differ as to the outcome." Id. at 77.

When a judgment as a matter of law is appealed to this court, we must apply precisely the same criteria that constrain the district court. See Gibson v. City of Cranston, 37 F.3d 731, 735 (1st Cir.1994). Accordingly, we review the grant of judgment as a matter of law under a de novo standard. See Jordan-Milton Mach., Inc. v. F/V Teresa Marie, II, 978 F.2d 32, 34 (1st Cir.1992).

II.

Mangla argues that judgment as a matter of law was inappropriate because a reasonable jury could find that Brown University breached a contract with Mangla by refusing to confer regular degree status upon him.

The district court, in this diversity case, was required to apply the substantive law of Rhode Island. However, after careful research, we have discovered no case in which the Rhode Island courts have addressed the contractual relationship between a private academic institution and its students. We therefore resolve Mangla's breach of contract claim according to those legal principles which we believe the Rhode Island courts would most likely adopt. See Lyons v. Salve Regina College, 565 F.2d 200, 202 (1st Cir.1977), cert. denied, 435 U.S. 971, 98 S.Ct. 1611, 56 L.Ed.2d 62 (1978).

The student-college relationship is essentially contractual in nature. See Russell v. Salve Regina College, 938 F.2d 315, 316 (1st Cir.1991). The terms of the contract may include statements provided in student manuals and registration materials. See Lyons, 565 F.2d at 202 (construing College Manual and Academic Information booklet as terms of a contract between a student and college). The proper standard for interpreting the contractual terms is that of "reasonable expectation--what meaning the party making the manifestation, the university, should reasonably expect the other party to give it." Id. (quoting Giles v. Howard University, 428 F.Supp. 603, 605 (D.D.C.1977)).

Mangla maintains that he reasonably expected that if he satisfactorily performed his course work and obtained a sponsor for his master's project he would be admitted as a master's degree candidate in the Computer Science Department. Mangla bases his claim on the alleged statements of Associate Dean Lusk and members of the Computer Science Department faculty. However, Brown University's graduate school catalog specifically provided:

Caveat. Applicants are asked to take particular notice of the fact that the individual academic...