Mathai v. Bd. of Sup’rs of Louisiana State Univ. (Summary)

SOVEREIGN IMMUNITY

Mathai v. Bd. of Sup’rs of Louisiana State Univ., No. 12-2778 (E.D. La. July 17, 2013)

The United States District Court for the Eastern District of Louisiana dismissed a suit against the board of a medical school and its dean by a former student who brought claims under §1983 and for breach of contract.  The student, who had a history of drug use that resulted in her entering into a continuation of enrollment contract with the school’s campus assistance program, was dismissed from the medical school after she refused to attend a three-month inpatient treatment program. The district court found the board, as an arm of the state, was immune from liability for the breach of contract and §1983 claims.  Similarly, the student’s claims for money damages against the dean were barred, as the court found he was acting in his official capacity as dean and was therefore protected by qualified immunity.  The student’s claims for injunctive relief against the dean were not barred by immunity, but the district court dismissed them nonetheless, finding that the student was not denied due process.