O'Shea v. George Mason University

82 Va. Cir. 566, 2007 Va. Cir. LEXIS 327
CourtFairfax County Circuit Court
DecidedJuly 13, 2007
DocketCase No. CL-2007-3421
StatusPublished

This text of 82 Va. Cir. 566 (O'Shea v. George Mason University) is published on Counsel Stack Legal Research, covering Fairfax County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'Shea v. George Mason University, 82 Va. Cir. 566, 2007 Va. Cir. LEXIS 327 (Va. Super. Ct. 2007).

Opinion

By Judge Jane Marum Roush

This matter came on for a hearing on June 22,2007, on the petitioner’s administrative appeal of the determination of George Mason University (GMU) that he is not a domiciliary of Virginia entitled to in-state tuition. At the time of the hearing, the court took the matter under advisement. I have now had the opportunity fully to review the administrative record, the briefs, and the case law submitted. For the following reasons, the petition will be denied.

Facts and Procedural History

The petitioner Edward O’Shea is a rising third-year law student at George Mason University School of Law. He is presently 31 years old and unmarried. O’Shea grew up in Texas. After college, he moved to New York in 1999 to join his parents. He applied to law schools in New York and was accepted at the law school of the University of Buffalo. He decided that he did not want to attend law school in Buffalo and did not matriculate. Instead, he stayed in New York for a year while he decided where he wanted to live. He applied for and was accepted to GMU’s law school. He moved to Virginia in July 2005 and began his studies as a full-time first-year law student at GMU in August 2005. O’Shea was classified as an out-of-state student for the 2005-2006 academic year.

In the Summer of 2006, O’Shea applied to be reclassified as a Virginia domiciliary for the Fall 2006 semester, based on his residence in Virginia for the previous twelve months. O’Shea is an “independent” student, meaning that he is self-supporting. He stated on his application [567]*567for a change of domicile that he moved to Virginia “to prepare to practice law in Virginia.” He stated that, in the previous twelve months, he had leased an apartment in Virginia, filed a tax return in Virginia, registered to vote in Virginia, held a Virginia driver’s license, and registered his car in Virginia. He also filed a tax return in New York as a partial year resident. He did not own land or a home in Virginia. He did not work in Virginia. He supported himself through the proceeds of student loans and his savings. Administrative Record, Tab 1.

O’Shea’s petition to be reclassified as an in-state student was denied at the initial decision level of GMU’s appeals process. Administrative Record, Tab 2. In his submissions to the intermediate appeals level, he stated that he moved to Virginia “to become a Virginia lawyer.” He described his plans after graduation as being to “practice law in Northern Virginia as part of the Commonwealth’s Attorney’s office or in a firm in the area.” He added that, in the Summer of 2006, he worked as an unpaid intern at the Circuit Court of Loudoun County, he paid personal property taxes in Virginia in 2005 and 2006, and he was an officer of the GMU chapter of the Virginia Bar Association. Administrative Record, Tab 3.

O’Shea’s petition to be reclassified as a Virginia domiciliary was denied by the intermediate appeals level, which ruled that:

Based upon the information that you submitted, it appeared that attending law school was a primary purpose for your moving to Virginia. The materials showed that you moved to the Commonwealth, after being admitted to the law school and approximately one month before you began full-time enrollment as [sic] at the law school. You have maintained full-time enrollment since then, except for summer. ... In addition, it appeared that some of the other factors presented for domicile may have been secondary or auxiliary to the full-time study of law.

Administrative Record, Tab 4.

O’Shea filed a request for reconsideration. He added to the information already submitted the fact that he “put off law school for a year in order to move to Virginia.” O’Shea explained that:

In stating that I moved to Virginia to become a Virginia lawyer, I did not mean that I had moved here to go to Law School. To the contrary, I put off Law School for a year so that I could move here. My intention was to move to an area where I could see myself settling down, raising a family, and also having a career that could support that.

[568]*568Administrative Record, Tab 5.

O’Shea’s request for reconsideration was denied by the intermediate appeals level. Administrative Record, Tab 6. He then appealed the decision to GMU’s Third Level Domicile Appeals Committee. O’Shea explained that his statement that he moved to Virginia to go to law school had been misinterpreted. He stated that:

[A]s a factual matter, attending law school was not a primary purpose in my decision to move to Virginia. I would have attended law school whether I moved to Virginia or not and actually deferred law school so that I could move to Virginia with the goal of settling in a place that I could see myself staying long-term.

Administrative Record, Tab 7. The Third Level Domicile Appeals Committee denied O’Shea’s petition, adopting the rationale of the intermediate appellate ruling. Administrative Record, Tab 8. O’Shea’s appeal to this court followed.

Applicable Law

Virginia Code § 23-7.4 and § 23.7.4:3(A) govern the resolution of O’Shea’s petition. Code § 23-7.4 provides, in pertinent part:

To become eligible for in-state tuition, an independent student shall establish by clear and convincing evidence that, for a period of at least one year immediately prior to the date of the alleged entitlement, he was domiciled in Virginia and had abandoned any previous domicile, if such existed... ,1
In determining domiciliary intent,2 all of the following applicable factors shall be considered: continuous residence for at least one year prior to the date of alleged entitlement, state to which income taxes are filed or paid, driver’s license, motor vehicle registration, voter registration, employment, property ownership, sources of financial support, military records, a written offer and acceptance of employment [569]*569following graduation, and any other social or economic relationships with the Commonwealth and other jurisdictions.
Domiciliary status shall not ordinarily be conferred by the performance of acts which are auxiliary to fulfilling educational objectives or are required or routinely performed by temporary residents of the Commonwealth. Mere physical presence or residence primarily for educational purposes shall not confer domiciliary status. A matriculating student who has entered an institution and is classified as an out-of-state student shall be required to rebut by clear and convincing evidence the presumption that he is in the Commonwealth for the purpose of attending school and not as a bona fide domiciliary.
Those factors presented in support of entitlement to instate tuition shall have existed for the one-year period prior to the date of the alleged entitlement.

Virginia Code § 23-7.4 (emphasis added).

Virginia Code § 23-7.4:3(A) provides, in pertinent part:

Any party aggrieved by a final administrative decision shall have the right to review in the circuit court for the jurisdiction in which the relevant institution is located. A petition for review of the final administrative decision shall be filed within thirty days of receiving the written decision.

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Related

Ravindranathan v. Virginia Commonwealth University
519 S.E.2d 618 (Supreme Court of Virginia, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
82 Va. Cir. 566, 2007 Va. Cir. LEXIS 327, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oshea-v-george-mason-university-vaccfairfax-2007.