Pierce v. Yale University

CourtDistrict Court, District of Columbia
DecidedJanuary 10, 2019
DocketCivil Action No. 2017-2508
StatusPublished

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

Bluebook
Pierce v. Yale University, (D.D.C. 2019).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

SAMUEL PIERCE,

Plaintiff,

v. Case No. 17-cv-02508 (CRC)

YALE UNIVERSITY, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiff Samuel Pierce wants to go to medical school. Denied admission by every school

to which he applied, Pierce turned to the courts for a cure. He began by filing a federal lawsuit

claiming that his rejection from Hofstra University’s medical school was the result of intentional

discrimination against “white Anglo-Saxon Protestant[s].” See Pierce v. Woldenburg, No. 11-

cv-4248, 2012 WL 3260316, at *1, *3 (E.D.N.Y. Aug. 7, 2012). After that case was dismissed,

Pierce unsuccessfully sued the University of California in state court, alleging he was denied

admission to UCLA’s medical school because of an “unlawful racial preference favoring

Hispanics.” See Pierce v. Regents of Univ. of Cal., B262545, 2016 WL 892015, at *4 (Cal. Ct.

App. Mar. 9, 2016). Undeterred, Pierce filed this case asserting a single claim under the

Sherman Act. A lawyer, but proceeding pro se, 1 Pierce here alleges that he was not admitted to

the Yale School of Medicine both because he is a white Republican and because of an antitrust

conspiracy between medical schools to share the names of successful applicants. The antitrust

1 Although Pierce did not go to medical school, he did attend law school and is barred in Maine. See ECF No. 4 at 21. conspiracy, Pierce contends, “enables” Yale and other schools to discriminate against otherwise

worthy applicants like him who do not share Yale’s purported ideological views.

Defendants have moved to dismiss Pierce’s amended complaint for lack of standing and

failure to state a claim. Defs.’ Mot. to Dismiss (“MTD”), ECF 12-1. Soon after they filed that

motion, Pierce moved to strike the discrimination allegations made in the complaint, to schedule

oral argument, or, in the alternative, to transfer the case to the District of Maine. Pl.’s Mot., ECF

No. 13. He has also moved for a scheduling order to allow limited discovery regarding his

antitrust claim. Pl.’s Am. Mot. for Scheduling Order, ECF No. 20. For the reasons that follow,

the Court will grant Defendants’ motion to dismiss and deny Pierce’s motions.

I. Background

As required on a motion to dismiss, the Court draws this factual background from the

complaint, assuming the truth of all well-pled allegations. See Sissel v. U.S. Dep’t of Health &

Human Servs., 760 F.3d 1, 4 (D.C. Cir. 2014). Defendants—Yale University (“Yale”), the

Trustees of the University of Pennsylvania (“Penn”), and the Association of American Medical

Colleges (“AAMC”) (collectively, “Defendants”)—naturally dispute many of Pierce’s

allegations. MTD at 5.

Pierce claims that he is “a magna cum laude graduate of Penn’s undergraduate program

who earned perfect scores on the Medical College Admissions Test.” First Am. Compl.

(“FAC”), ECF No. 4, ¶ 6. He applied to a number of medical schools between 2009 and 2015

using AAMC’s application system. Id. ¶ 36. Pierce was one of approximately 700 applicants

selected to interview at Yale in 2015. Id. ¶¶ 6, 56. He was not, however, offered admission to

Yale or any other school to which he applied. Id. ¶ 38.

2 Pierce raises a single claim under Section 1 of the Sherman Act, 15 U.S.C. § 1. FAC

¶¶ 65–73. He frames his complaint as a challenge to a conspiracy between medical schools,

including Yale and Penn, and AAMC to share the names of successful applicants on the Multiple

Acceptance Report (“MAR”), a list that Pierce says is circulated among schools during each

application cycle. Id. ¶ 2. He identifies three anti-competitive effects of this alleged

information-sharing conspiracy: (1) increased tuition because accepted students have less

bargaining power to negotiate financial-aid packages; (2) decreased overall acceptances because

schools are better able to anticipate matriculation rates and avoid over-enrollment; and (3)

decreased consumer choice because schools are less likely to extend offers to students already

accepted elsewhere. Id. ¶ 4. He insists that he would have gotten into the medical schools to

which he applied, including Yale, if not for the MAR conspiracy. Id. ¶¶ 6, 41.

Yet Pierce spends much of the complaint discussing another alleged cause of his

rejection: “invidious” discrimination. Id. ¶ 55; see also id. ¶¶ 30, 46–64. Pierce alleges that Yale

“stack[ed] the deck against persons of Plaintiff’s race” (white) and political party (Republican).

Id. ¶ 66. As evidence, he maintains that Yale seeks to achieve “thinly veiled, rigid racial quotas”

and that “a Black applicant is far more likely to be admitted to medical school than a White

applicant.” Id. ¶¶ 50, 53. Pierce alleges that Yale also seeks to achieve “ideological uniformity,”

as demonstrated by statements on its website expressing support for the Affordable Care Act

(“ACA”). Id. ¶¶ 57–58. AAMC likewise exhibits “bias against Republicans,” as indicated by an

e-mail it circulated in June 2017, also expressing support for the ACA. Id. ¶ 59. Yale’s bias was

on display during his 2015 interview, Pierce says, when “he was interrogated . . . regarding his

political preferences.” Id. ¶ 55. He suggests that “Black and Hispanic applicants (who are

assumed to share Yale’s required [liberal] ideology)” were not similarly interrogated. Id.

3 According to Pierce, this political and racial discrimination led Yale to reject his

application despite his “extraordinary talents,” id. ¶ 71:

A separate admissions track applied to the Plaintiff where [he] was expected to produce incontrovertible evidence that he had no inklings of support for the Republican Party or any ideas associated with it, which did not apply to any Black applicants. The Plaintiff could not do so. Shortly after interviewing . . . , Yale informed Plaintiff that it was denying Plaintiff admission to the medical school.

Id. ¶ 55. Pierce broadly alleges that the MAR “enables this sort of political and racial

discrimination” because without access to the information on that report, “market forces [would]

constrain the ability of universities to exact retribution on the Plaintiff (and others

demographically similar to him) for the perceived sins of his ancestors.” Id. ¶ 56. To support

this assertion, Pierce spins out a “mathematical model” in his complaint which estimates that,

absent the MAR, Yale would have to more than double the number of students it admits in order

to achieve its target class size. Id. ¶ 41. Under this model, Pierce contends that Yale “would

have necessarily admitted” him had it not received the MAR. Id. ¶¶ 6, 41.

II. Standard of Review

Defendants move to dismiss the complaint for lack of subject matter jurisdiction pursuant

to Federal Rule of Civil Procedure 12(b)(1) and for failure to state a claim under Rule 12(b)(6).

When analyzing a motion to dismiss under either Rule 12(b)(1) or 12(b)(6), the “court assumes

the truth of all well-pleaded factual allegations in the complaint and construes reasonable

inferences from those allegations in the plaintiff’s favor, but is not required to accept the

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