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Keywords

contractlawsuitbreach of contractplaintiffstatutecompliancedue process
contractplaintiffdue process

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Conard v. University of Washington, 119 Wash.2d 519, 834 P.2d 17, 76 Ed. Law Rep. 584

Facts

In February 1983, Kevin Conard and Vincent Fudzie were recruited by the University of Washington (UW) to play football and received offers of athletic financial assistance for three consecutive quarters. The offers included provisions for renewal based on good standing and compliance with eligibility requirements. However, both players engaged in a series of misconduct incidents, leading to their removal from the team and the non-renewal of their scholarships. They subsequently filed a lawsuit against UW for breach of contract and interference with contractual relations after their scholarships were not renewed.

In February 1983, petitioners Kevin Conard and Vincent Fudzie (plaintiffs) were recruited by the University of Washington (UW) to play football. Both plaintiffs signed national letters of intent and received offers of athletic financial assistance for three consecutive quarters commencing the first day of class of the fall quarter of the 1983 academic year.

Issue

Did the University of Washington violate the plaintiffs' due process rights by not renewing their athletic scholarships?

Did the University of Washington violate the plaintiffs' due process rights by not renewing their athletic scholarships?

Rule

The scope of the Fourteenth Amendment's procedural protection of property interests is not coextensive with contract rights. Protected property interests may arise from statutes or rules that provide substantive predicates or specific criteria guiding decision-makers. A legitimate claim of entitlement must be established through clear terms or mutual understandings, which were not present in the contracts for the renewal of athletic scholarships.

The scope of the Fourteenth Amendment's procedural protection of property interests is not coextensive with contract rights; terms of contract may be source of property interest, but protected property interests include all benefits to which there is legitimate claim of entitlement. U.S.C.A. Const.Amend. 14.

Analysis

The court analyzed whether the terms of the financial aid contracts created a protected property interest in the renewal of scholarships. It concluded that the contracts explicitly stated the aid was for three consecutive quarters and that renewal was not guaranteed but merely considered based on certain conditions. The players' claims of a common understanding for renewal were unsupported by evidence of explicit agreements or university policies that would create a legitimate claim of entitlement.

Unless a legitimate claim of entitlement to the renewal of plaintiffs' scholarships was created by the terms of the contract, by a mutually explicit understanding, or by substantive procedural restrictions on the part of the decision maker, plaintiffs have no constitutional due process protections.

Conclusion

The court affirmed in part and reversed in part, holding that the players did not have a protected property interest in the renewal of their scholarships due to the lack of clear contractual terms or mutual understandings.

Affirmed in part and reversed in part.

Who won?

The University of Washington prevailed in this case as the court found that the players did not have a legitimate claim of entitlement to the renewal of their scholarships. The court determined that the terms of the financial aid contracts were clear in stating that the aid was for a limited duration and that renewal was not guaranteed. The players' claims of a common understanding regarding scholarship renewal were deemed insufficient to establish a protected property interest.

The University of Washington prevailed in this case as the court found that the players did not have a legitimate claim of entitlement to the renewal of their scholarships.

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