Murphy v. Franklin Pierce

CourtDistrict Court, D. New Hampshire
DecidedNovember 17, 1994
DocketCV-93-65-B
StatusPublished

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

Bluebook
Murphy v. Franklin Pierce, (D.N.H. 1994).

Opinion

Murphy v . Franklin Pierce CV-93-65-B 11/17/94 P UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Nancy D. Murphy

v. Civil N o . C-93-65-B Franklin Pierce Law Center

MEMORANDUM AND ORDER

Nancy Murphy suffers from a chronic vision impairment known

as diplopia.1 After being dismissed as a Franklin Pierce Law

School student, she sued the Law Center alleging that she was the

victim of unlawful discrimination on the basis of her disability

and sex in violation of § 504 of the Rehabilitation Act of 1973,

29 U.S.C.A. § 794 (West Supp. 1994), Title IX of the Education Amendments of 1972, 20 U.S.C.A. § § 1681 and 1682 (West 1990),

and the Fourteenth Amendment's Equal Protection Clause. She also

alleged that the Law Center's discharge procedures violated her

rights under the Fourteenth Amendment's Due Process Clause and

state contract law. The matter is before me on the parties'

cross-motions for summary judgment.

1 Diplopia is caused by congenital weakness of the muscles controlling convergent focus of the eyes. According to the plaintiff, this condition severely hinders her ability to focus on printed material. I. FACTS

A. Franklin Pierce Law Center

Franklin Pierce Law Center is a private, nonprofit

corporation that receives some federal financial assistance. The

Law Center does not offer a part-time program and, with limited

exceptions, it requires students to complete their degree

requirements within three years.

Franklin Pierce publishes rules that limn its academic

requirements and procedures for disciplinary action. The rules

require that students must maintain a grade point average ("GPA")

of 2.00 or higher, earn at least eighty-four credits, with no

more than nine of those credits falling below a grade of C-, and

satisfy any terms of academic probation. If a student fails to

meet these minimum standards, he or she is subject to the oversight of the school's Academic Standards Committee. Students

within the Committee's jurisdiction may be placed on probation,

suspended, or dismissed. Probationary students must submit a

plan to the Committee explaining their poor performance and

offering recommendations for corrective action. The Committee

may accept, modify or reject a student's plan when setting

probation terms. It may also subject probationary students to

revised eligibility requirements.

2 B. Murphy's First Year: Fall 1987 - Spring 1988

Murphy disclosed her visual impairment in her admission

application. She described her condition as double vision that

first manifested itself when she was a teenager. She claimed

that the condition worsened significantly after she was involved

in an automobile accident during her second year of college.

After undergoing two surgical procedures and "ocular motility

therapy," however, she claimed that she no longer needed

eyeglasses and concluded that "I continue today to read well

without impairment." Murphy thus presented her condition as a

hurdle that she had overcome rather than an impairment that would

require accommodation upon admission.

Franklin Pierce admitted Murphy for the Fall 1987 term. She

took the same fifteen-credit course load as the other first year students, but was placed on probation after her second semester

because her cumulative GPA was below 2.00. In accordance with

the Law Center's rules, Murphy submitted a corrective action plan

to the Academic Standards Committee. She did not allege that her

low GPA had been caused by her visual impairment. Instead, she

attributed her performance to poor test taking skills, panic when

taking exams, "culture shock," and a thyroid condition.

3 The Committee responded by accepting Murphy's proposed class

schedule for the fall term. In light of her self-described

"panic," however, the Committee required her to take practice

exams throughout the semester. It also informed her that she

must earn no grade less than C-, achieve at least a 2.00 GPA for

the fall semester, and raise her cumulative GPA to 2.00 by the

end of her second year. Finally, in commenting upon her thyroid

condition, the Committee informed her that "[f]or our part, while

sympathetic to the health problems you have, and willing to

consider accommodations before health problems impact on

performance, we do not see them as a basis for lessening of

standards and will not be able to waive these terms of probation

should you come to us after the fact with the explanation that

you could have done better except for ill health."

C. Murphy's Second Year: Fall 1988 - Spring 1989 Murphy successfully completed her probationary requirements

for the Fall 1988 semester, receiving a GPA of 2.08. However,

the Academic Standards Committee required her to submit another

corrective action plan at the end of her second year because she

received a D in Evidence and thereby violated the Law Center's

rule prohibiting students from having more than nine credits

below C-.

4 Murphy alleged for the first time in her second corrective

action plan that her academic difficulties were due in part to

her visual impairment. She also described her condition in

detail and delineated her method of managing the condition

through muscle therapy, diet, rest, reading time management, and

the occasional use of prism lenses. She further stated that her

doctor recommended "being awake for three hours in the morning

before reading, and sleeping when I have difficulty converging or

when I experience muscle strain."2 Because Murphy claimed that

her impairment caused her to experience pain and headaches, she

requested three-day rest periods between exams to allow her time

to rest and manage her reading schedule without strain. She also

stated "[a]lthough I have not previously brought this to the

attention of the Academic Standards Committee, I did write

briefly about the condition in my personal statement. I also spoke about it with Professor Arpiar Saunders during my admission

interview."

2 In an August 1 1 , 1989 letter, Murphy's doctor informed her: "I would suggest that you avoid situations that are particularly stressful to your eyes, such as taking several examinations in rapid succession. As a matter of fact, it would be advisable that you break up your study and reading into well defined segments of time such as two hours at a time, or three hours at the most, and I hope that you will be able to avoid the development of headaches and assorted problems."

5 The Committee accepted Murphy's explanation for her poor

performance and allowed her to return for a fifth semester.

However, it again placed her on probation. This time, the

Committee required her to achieve a GPA of 2.30 or higher for

each semester of her third year, receive no D's or F's, and no

more than one C- in either semester, and submit a proposed course

schedule for the Committee's approval. The Committee also

informed her that "if these conditions are not met, we will not

entertain any new plans for rehabilitation, i.e., you will be

dismissed if these terms are not met."

Murphy chose not to appeal the Committee's decision and

instead began negotiations with the Committee concerning her fall

courses.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

School Bd. of Nassau Cty. v. Arline
480 U.S. 273 (Supreme Court, 1987)
Treadwell v. Alexander
707 F.2d 473 (Eleventh Circuit, 1983)
United States v. Jose M. Cruz Jimenez
894 F.2d 1 (First Circuit, 1990)
United States v. Ilario M.A. Zannino
895 F.2d 1 (First Circuit, 1990)
Samuel Mesnick v. General Electric Company
950 F.2d 816 (First Circuit, 1991)
Evelyn Dejesus v. Banco Popular De Puerto Rico
951 F.2d 3 (First Circuit, 1991)
Alan Taub v. Anthony Frank
957 F.2d 8 (First Circuit, 1992)

Cite This Page — Counsel Stack

Bluebook (online)
Murphy v. Franklin Pierce, Counsel Stack Legal Research, https://law.counselstack.com/opinion/murphy-v-franklin-pierce-nhd-1994.