Board of Trustees of the University of the District of Columbia v. The Joint Review Committee on Education in Radiologic Technology

CourtDistrict of Columbia Court of Appeals
DecidedMay 21, 2015
Docket14-CV-752
StatusPublished

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Board of Trustees of the University of the District of Columbia v. The Joint Review Committee on Education in Radiologic Technology, (D.C. 2015).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 14-CV-752

BOARD OF TRUSTEES OF THE UNIVERSITY OF THE DISTRICT OF COLUMBIA, APPELLANT,

v.

THE JOINT REVIEW COMMITTEE ON EDUCATION IN RADIOLOGIC TECHNOLOGY, APPELLEE.

Appeal from the Superior Court of the District of Columbia (CAB-3793-12)

(Hon. Michael L. Rankin, Trial Judge)

(Argued February 26, 2015 Decided May 21, 2015)

Daniel D. Mauler, with whom Yoora Pak and Smruti Radkar were on the brief, for appellant.

Michael A. Montgomery, of the bar of the State of Virginia, pro hac vice, by special leave of court, with whom Edward J. Longosz, II, and Sarah Shyr were on the brief, for appellee.

Before GLICKMAN and FISHER, Associate Judges, and STEADMAN, Senior Judge.

STEADMAN, Senior Judge: After offering courses in radiology for almost

forty years, the University of the District of Columbia (“UDC”) lost its

accreditation in that field by action of the Joint Review Committee on Education in 2

Radiologic Technology (“JRCERT”). The issue in this appeal by UDC is whether,

as the trial court held, exclusive jurisdiction over its dispute with JRCERT is

vested in the federal courts. We hold that it is and therefore affirm the trial court’s

dismissal of UDC’s third-party complaint against JRCERT for lack of jurisdiction.

I.

JRCERT is the only agency recognized by the U.S. Department of

Education and the Council for Higher Education Excellence to accredit programs

in radiography, radiation therapy, magnetic resonance, and medical dosimetry.

Only students who graduate from a program while it is certified by JRCERT are

considered graduates of a JRCERT accredited program. Students who fail to

graduate from a JRCERT accredited program cannot sit for the national board

certification examination.

JRCERT continuously accredited UDC’s Medical Radiography Program

(“the Program”) from 1971 to April 23, 2010. On that date, JRCERT’s Board of

Directors voted to involuntarily withdraw the Program’s accreditation, effective

April 23, 2010. UDC did not seek re-accreditation. 3

Two years later, on May 2, 2012, Ahmednur Fella, a student at UDC who

had graduated from the Program on May 8, 2010, filed a lawsuit against UDC

alleging breach of contract, fraud, and negligent misrepresentation arising from the

revocation of accreditation. UDC then filed a third-party complaint against

JRCERT under Rule 14 of the Superior Court Rules of Civil Procedure, alleging a

wide variety of state law claims.1 The trial court granted JRCERT’s motion to

dismiss the third-party complaint on the ground that 20 U.S.C. § 1099b (f) (2012),

a provision of the Higher Education Act of 1965 (“HEA”), as amended, conferred

exclusive jurisdiction over the dispute in the federal courts.2 We turn to that issue.

1 These included breach of contract, breach of implied contract, tortious interference with economic relationships, negligence, breach of fiduciary duty, promissory estoppel, intentional misrepresentation, negligent representation, contribution from JRCERT, and equitable indemnification from JRCERT. 2 In doing so, the trial court relied on a prior Superior Court opinion in another suit by a UDC student in the Program. Berhanu Worku v. Board of Trs. of the Univ. of the District of Columbia (“Worku”), No. 2013 CA 002822 B, Order (D.C. Super. Ct. Nov. 7, 2013). UDC objects to the trial court’s reliance on the prior court’s opinion without considering its subsequent arguments, but we review judgments, not opinions. District Intown Props., Ltd. v. District of Columbia Dep’t of Consumer & Regulatory Affairs, 680 A.2d 1373, 1377 n.5 (D.C. 1996). Plaintiff Fella and UDC settled their dispute and the underlying case was dismissed, leaving only the dispute over the third-party complaint. The issue of exclusive jurisdiction vel non, however, remains relevant to several other similar cases still pending in Superior Court. 4

II.

The disputed provision relating to the issue of exclusive jurisdiction came

into being as part of the 1992 amendments to the Higher Education Act of 1965

and reads as follows (20 U.S.C. § 1099b (f)):

Notwithstanding any other provision of law, any civil action brought by an institution of higher education seeking accreditation from, or accredited by, an accrediting agency or association recognized by the Secretary for the purpose of this subchapter and part C of subchapter I of chapter 34 of Title 42 and involving the denial, withdrawal, or termination of accreditation of the institution of higher education, shall be brought in the appropriate United States district court.

We address the interpretation of this provision against the backdrop of the

principle that “state courts have inherent authority, and are thus presumptively

competent, to adjudicate claims arising under the laws of the United States.”

Tafflin v. Levitt, 493 U.S. 455, 458 (1990). “This deeply rooted presumption in

favor of concurrent state court jurisdiction is, of course, rebutted if Congress

affirmatively ousts the state courts of jurisdiction over a particular federal claim.”

Id. at 459. Congress can oust a state court of concurrent jurisdiction either

explicitly or implicitly. “[T]he presumption of concurrent jurisdiction can be

rebutted by an explicit statutory directive, by unmistakable implication from 5

legislative history, or by a clear incompatibility between state-court jurisdiction

and federal interests.” Id. at 459-60 (quoting Gulf Offshore Co. v. Mobil Oil Corp.,

453 U.S. 473, 478 (1981)).3 Following the Supreme Court’s lead, we now proceed

to examine whether exclusive jurisdiction in the federal courts is found either by

“an explicit statutory directive” or by “unmistakable implication from legislative

history.” As will be shown, we believe both inquiries lead to the conclusion of

exclusivity.4

A.

We first examine the “explicit statutory directive.” On its face, it appears to

be an instruction in seemingly unequivocal terms. “Notwithstanding any other

provision of law,” a covered civil action “shall”—not “may”—be brought in the

appropriate United States District Court. 20 U.S.C. § 1099b (f). Appellant,

however, points out that the statute does not employ the words “exclusively” or

“only” and draws our attention to federal cases that have interpreted somewhat

3 We proceed under the assumption, with which we see no reason to quarrel, that for present purposes, the District of Columbia courts are to be treated as those of a state. 4 We therefore need not consider the third possibility that may show exclusive jurisdiction as a result of “a clear incompatibility between state-court jurisdiction and federal interests.” 6

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