Niman v. Christian

CourtDistrict Court, D. Montana
DecidedJanuary 6, 2025
Docket9:23-cv-00079
StatusUnknown

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

Bluebook
Niman v. Christian, (D. Mont. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA MISSOULA DIVISION

BETHANY NIMAN, et al., CV 23~79-M-~DWM Plaintiffs, Vs. OPINION and ORDER CLAYTON CHRISTIAN, et al., Defendants.

Plaintiffs are students and former students who enrolled in professional degree programs at the University of Montana—Missoula (“UM”) that were classified as non-resident students for the purposes of their tuition and fees. They have sued the Montana Commissioner of Higher Education Clayton Christian, as well as individual members of the Montana Board of Regents and UM registrars, (collectively, “Defendants”), alleging civil rights violations under 42 U.S.C. §§ 1983 and 1988 based on a residency policy that denies bona fide residents of Montana in-state tuition at its universities. (Doc. 1.) Both parties have moved for summary judgment. (Docs. 36, 39.) A motion hearing was held on November 22, 2024.' Summary judgment is granted in favor of Defendants.

That hearing also addressed class certification, which was denied. (See Doc. 51.)

BACKGROUND? I. The Residency Policy Montana Board of Regents of Higher Education Residency Policy 940.1 (the “Policy”) prescribes the procedure for determining the in-state or out-of-state classification of applicants for admission at the campuses of the Montana University System. (See Docs. 15-1, 15-2.) Generally, students may only be classified as in-state after providing documentation that they have been domiciled in Montana for at least 12 consecutive months. (See Doc. 15-2 at 1.) “Domicile requires both physical presence and evidence of intent to stay,” and “[e]vidence of intent to stay includes relinquishing all valid legal ties with a former state of residence and affirmatively creating legal ties and relationships with Montana.” (id.) The Policy requires specific connections to Montana that must be established at least 12 consecutive months before the term for which the student is seeking in- state status. Establishing these requirements can include registering a motor vehicle in Montana, getting a Montana driver’s license, and registering to vote in Montana. (/d.) The Policy contains additional requirements for in-state students who claim financial independence from out-of-state income, which requires they receive “less than 50% of all income and financial support from” out-of-state and

* The facts are undisputed unless otherwise noted. (See Docs. 37, 41, 45, 48.)

pay for “the majority of their expenses (including the cost of attendance and room/board) with their own independent income and resources.” (Jd. at 2.) When considering evidence for residency classification, the Policy applies several presumptions, one is that an individual cannot establish residency for tuition purposes while registered for more than half of a full-time credit load because such a presence is considered “primarily for educational purposes.” (id. at 3.) “A presumption can be overcome with clear and convincing evidence, which is evidence in which there is no serious or substantial doubt about the correctness of the conclusions drawn from the evidence.” (/d.) A student classified as a non- resident remains a non-resident unless the student successfully petitions for reclassification. (/d. at 5.) A student adversely affected by the final decision of a relevant campus may appeal the decision to the Commissioner of Higher Education, and the Commissioner’s decision may be appealed to the Board of Regents. (See Doc. 15-4.) No hearing is required on appeal. (/d. at 2.) The Policy contains specific provisions governing the classification of professional degree program students—i.e., students enrolled in a program of law, pharmacy, or physical therapy. Prior to July 2023, Rule 940.1(H) provided in relevant part: An out-of-state student admitted to a professional degree program is not eligible for reclassification as an in-state resident and shall remain classified as an out-of-state student for the duration of the student’s enrollment in the professional degree program. A student classified as

out-of-state who maintains the initial classification was in error may only seek reclassification pursuant to the procedures of this policy prior to the start time of the initial term of enrollment or matriculation into the program. (Doc. 15-1 at 3-4.) This language was amended in July 2023, and now reads: To be eligible for in-state status, a student admitted to a professional degree program must meet the standards set forth in subsection C-E {described above at 2—3]. In addition, the student must have maintained a primary residence in Montana for at least 12 consecutive months immediately before the student’s first admitted semester. The Montana residence must be for the purposes other than postsecondary education. If the student took more than 7 credits (or more than 8 credits on a block schedule) at an institution of higher education during the 12-month period, the student must prove by clear and convincing evidence that the student has a Montana residence for reasons other than postsecondary education. This subsection does not apply to students who can demonstrate previous Montana residency under this policy and who have not abandoned residency. For the purposes of this section, the term “professional degree program” means a program of law, pharmacy, or physical therapy. (Doc. 15-2 at 3 (Rule 940.1(G)).) Unless specifically distinguished in context, these provisions are referred to as the “professional student provisions” below. Il. Plaintiffs Plaintiffs are nine former students of UM that were enrolled in a professional degree program. With the exception of one Plaintiff, who read the Policy and decided against applying for reclassification, Plaintiffs claim that, although they were “bona fide” residents of Montana, they were denied in-state resident status reclassification based on one or more of the following allegedly unconstitutional requirements: (1) the 12-month waiting period; (2) the pursuit of a

professional degree; (3) the credit load presumption; or (4) financial dependence on an out-of-state source. Plaintiffs also claim they were charged out-of-state tuition disproportionate to the funding provided by Montana taxpayers. All nine Plaintiffs have graduated, (see Doc. 32-18 at 2), and all but one either live or work outside Montana. Plaintiffs are discussed individually below. A. Bethany Niman (Law) Niman moved from Oklahoma to Montana in July 2021 and began law school at UM in August 2021. (Doc. 32-2 at 12-13.) While Niman had applied to numerous law schools in the West, she specifically wanted to move to, and live in, Montana. (id. at 15-16.) Niman attended law school at UM in 2021, 2022, and 2023, graduating in December 2023. (id. at 16-17.) While Niman testified in her deposition that all through school she intended to live in Montana once she graduated, (id. at 17), she attempted to transfer law schools after her first year, (id. at 26; Doc. 32-17 at 11). Niman maintains, however, that she would have returned to Montana after school. (See Doc. 32-2 at 28-29.) Niman did not register to vote in Montana until April 2022. (/d. at 44; Doc. 32-3 at 2.) She worked in Montana while in law school, (Doc. 32-2 at 33-34), and filed taxes in Montana, (id. at 43), but following her graduation in December 2023, applied for legal jobs primarily outside Montana, (id. at 35-40; see Doc. 32-3 at 3-16 (Indeed application list)). While Niman currently resides in Montana and plans to continue to do so, (Doc.

32-2 at 49), she works as a deputy prosecutor in Bonneville County, Idaho on a

one-year contract, (see id. at 11; see Doc. 34-2 at 2).

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Niman v. Christian, Counsel Stack Legal Research, https://law.counselstack.com/opinion/niman-v-christian-mtd-2025.