Thomas M. Cooley Law School v. American Bar Association
United States Court of Appeals for the Sixth Circuit
459 F.3d 705 (2006)
The American Bar Association (defendant), which held delegated accreditation authority from the Secretary of Education, allowed schools to run up to 20 percent of their program at a satellite campus without triggering "major change" review; Thomas M. Cooley Law School (plaintiff) sought accreditation for two new satellite campuses but began operating them above that 20-percent threshold while its application was still pending. The ABA gave advance notice of a show-cause hearing, let Cooley present its case, and issued a final reasoned report censuring Cooley and barring the satellite campuses' operation until 2006; Cooley sued alleging a violation of its common-law due-process right, and the district court granted the ABA summary judgment.
Whether, in analyzing whether a quasi-governmental agency violated a person's due-process rights, courts apply principles of administrative law to determine whether the quasi-governmental agency conformed its actions to fundamental principles of fairness.