Freeman v. New York University

CourtDistrict Court, S.D. New York
DecidedFebruary 14, 2022
Docket1:21-cv-01029
StatusUnknown

This text of Freeman v. New York University (Freeman v. New York University) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Freeman v. New York University, (S.D.N.Y. 2022).

Opinion

74 SH nee Seen tay [Use SUNNY enna UNITED STATES DISTRICT COURT i PROC E Ny SOUTHERN DISTRICT OF NEW YORK MLS VR aa, PP yo LAG Ly ey □□□□ al aa □□ Or) eT aS a? JEROLD FREEMAN, KAREN KUO, RAJVEER GATE PLROEERT po: SACHDEV, PEIHU WANG, and ANDREW WOLFF, on: common EB. 49099 i their own behalf and on behalf of those similarly situated,: Plaintiffs, : MEMORANDUM DECISION -against- : : AND ORDER NEW YORK UNIVERSITY, : 21 Civ. 01029 (GBD) Defendant. : ter re rr re rrr rete rere re rere rere eee HX GEORGE B. DANIELS, United States District Judge: This is another putative class action in which students at New York University have sued the university for breach of contract, unjust enrichment, and conversion over its decision to suspend in-person academic instruction in response to the COVID-19 pandemic. Defendant NYU moved to dismiss Plaintiffs’ Complaint. Because the Complaint suffers from the same deficiencies as those in Zagoria v. New York University, No. 20-cv-3610 (GBD), 2021 WL 1026511 (S.D.N.Y Mar. 17, 2021), and similar cases, the Court reaches the same conclusion and GRANTS Defendant’s motion to dismiss the Complaint in its entirety.! I FACTUAL BACKGROUND The facts of this case are straightforward and resemble those presented in other similar cases suing NYU. (Mem. of Law in Opp’n to Def.’s Mot. to Dismiss (the “Opposition”), ECF No. 21, at 26.) Plaintiffs were enrolled at NYU, in the Stern School of Business, Executive MBA Program, during the Spring and Summer 2020 academic semester. (Complaint, ECF No. 1-1, {J

' The Court has assessed similar complaints in Morales v. New York Univ., No. 20-cv-4418 (GBD), 2021 WL 1026165 (S.D.N.Y. Mar. 17, 2021) and Romankow v. New York Univ., 20-cv-4616 (GBD), 2021 WL 1565616 (S.D.N.Y. Apr. 20, 2021).

15-17.) On March 16, 2020, in response the COVD-19 global pandemic, NYU announced that “all in-person classes would be suspended effective immediately.” (Ud. 423.) Plaintiffs maintain that the suspension of in-person instruction resulted in Defendants not providing “the educational services, facilities, access and/or opportunities that Plaintiffs ... contracted and paid for.” (Compl. at § 25.) Because NYU continued to charge full tuition and fees for the Spring and Summer 2020 semester despite transitioning to online instruction, Plaintiffs now seek a pro-rated refund of “tuition and fees proportionate to the amount of time that remained in the Spring and Summer Semester 2020” once in person instruction ceased. (/d. § 30.) Specifically, Plaintiffs bring claims for (1) breach of contract; (2) unjust enrichment; and (3) conversion. NYU moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). (Mot. to Dismiss, ECF No. 17.) Il. LEGAL STANDARD “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 US. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). The plaintiff must demonstrate “more than a sheer possibility that a defendant has acted unlawfully;” stating a facially plausible claim requires the plaintiff to plead facts that enable the court “to draw the reasonable inference that the defendant is liable for the misconduct alleged.” /d. (citation omitted). The factual allegations pled must therefore “be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555 (citation omitted). A court makes this assessment by striking any conclusory allegations and then considers whether the plaintiff's remaining well- pleaded factual allegations, assumed to be true, “plausibly give rise to an entitlement to relief.” 556 U.S. at 679. In deciding the 12(b)(6) motion, the court must also draw all reasonable

inferences in the non-moving party's favor. See N.J. Carpenters Health Fund v. Royal Bank of Scot. Grp., PLC, 709 F.3d 109, 119-20 (2d Cir. 2013). “Generally, consideration of a motion to dismiss under Rule 12(b)(6) is limited to consideration of the complaint itself.” Faulkner v. Beer, 463 F.3d 130, 134 (2d Cir. 2006). However, there are instances in which it is appropriate to consider matters outside of the pleading. Courts can consider materials where the complaint “relies heavily upon its terms and effect, thereby rendering the document integral to the complaint” or “any statements or documents incorporated in it by reference.” Nicosia v. Amazon.com, Inc., 834 F.3d 220, 230 (2d Cir. 2016) (quotations omitted). If a court is to consider extraneous material that is considered “integral” to the complaint, “it must be clear on the record that no dispute exists regarding the authenticity or accuracy of the document.” (/d.) (quotations omitted). I. PLAINTIFF’S CLAIMS ARE DISMISSED The legal analysis and applicable substantive law in Zagoria applies with even more weight here in dismissing the Complaint. A. The Court Can Consider the Additional Materials. First, the Court can consider the additional facts asserted in the Plaintiffs’ and Defendant’s papers, such as additional websites, university handbooks, declarations, and disclaimer clauses in the NYU Bulletin, because they are integral to or referenced in the complaint. The declarations come from named Plaintiffs thus it is reasonable to believe these statements are incorporated in the Complaint by reference. Second, the other materials are integral and other courts, when reviewing similar claims, have considered such additional materials. See Bergeron v. Rochester Inst. of Tech, No. 20-CV-6283 (CJS), 2020 WL 7486682, at *6 (W.D.N.Y. Dec. 18, 2020).?

* The foregoing analysis of the Complaint includes these additional materials even when the Court does not specifically reference whether the facts are pleaded on the face of the Complaint.

B. Plaintiffs Fail to Plead Facts Demonstrating a Contract. Even when considering all additional facts, the Complaint completely fails to plead any specific promise by NYU to provide exclusively in-person instruction. After disregarding all conclusory statements, Plaintiffs’ breach of contract claim is primarily based on vague references to materials that “market{] the NYU on-campus experience as a benefit of enrollment” and an ‘admission agreement.” (Compl. §§ 27, 44.) Such vague references are axiomatic of a failure to demonstrate any express language identifying a “specifically designates and discrete promise” of in-person classes. Zagoria, 2021 WL 1026511, at *4; see also Morales v. New York University, No. 20-cv-4418 (GBD), 2021 WL 1026165, at *1 (S.D.N.Y. Mar. 17, 2021) (dismissing a complaint for failure to demonstrate a specific promise based on statements made in NYU’s course catalog and advertising materials, such as brochures and websites) (hereinafter “Morales I’); Hassan v. Fordham University, 2021 WL 293255, at *5 (S.D.N.Y. Jan. 28, 2021) (dismissing breach of contract claim because “none of the[] statements [identified by the plaintiff]...constitutes a specific promise on Fordham’s part to provide” in-person instruction). Plaintiffs’ rely on statements in NYU’s Handbook, such as attendance and device policies, and facts asserted in declarations to support their vague references. (Opp.at 1,3, 4 8,9, 12.) These additional facts still fail to identify specific statements showing a promise to provide in-person instruction and do not save the complaint from the same fate as similar complaints before it.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Jeffers v. American University of Antigua
125 A.D.3d 440 (Appellate Division of the Supreme Court of New York, 2015)
Faulkner v. Beer
463 F.3d 130 (Second Circuit, 2006)
Nicosia v. Amazon.com, Inc.
834 F.3d 220 (Second Circuit, 2016)

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Bluebook (online)
Freeman v. New York University, Counsel Stack Legal Research, https://law.counselstack.com/opinion/freeman-v-new-york-university-nysd-2022.