Charleston v. Bd. of Trustees of the University of Illinois-Chicago

Dist. Ct. did not err in dismissing for failure to state valid cause of action plaintiff-student’s section 1983 action, alleging that defendant-university violated his substantive and procedural due process rights, when it dismissed him from medical school for alleged unprofessional conduct. Plaintiff failed to establish any protected property interest in his continued education for purposes of establishing due process claim, and plaintiff failed to otherwise allege that defendant had entered into express or implied contract. Fact that instant dismissal may have violated defendant’s internal procedures, as set forth in its disciplinary policy, does not require different result. Plaintiff also failed to state viable equal protection claim, where plaintiff failed to identify similarly-situated student, who had committed similar academic short-comings and who received more favorable treatment.