Osteen v. Henley
United States Court of Appeals for the Seventh Circuit
13 F.3d 221 (1993)
Northern Illinois University expelled Thomas Osteen (plaintiff) for two years after he physically harmed two other students in a fight; the university mailed him notice and its judicial code, he met with a judicial officer and pleaded guilty to the charges while requesting a hearing on the sanction, and an appeals board (attended by Osteen and a student advocate, though not an attorney) upheld the two-year expulsion after considering statements and character references, a decision later upheld on internal appeal. Osteen sued the university (defendant), claiming the expulsion deprived him of property without due process because he had no right to counsel during the proceeding, and the district court dismissed his suit.
Whether the Due Process Clause guarantees a student a right to counsel in a university disciplinary proceeding resulting in nonpermanent expulsion.