Hickey v. University Of Pittsburgh
77 F.4th 184 (3rd Cir. 2023)
Nature Of The Case
This section contains the nature of the case and procedural background.
Facts
Ds are universities (University of Pittsburgh and Temple University) that offer traditional, on-campus educational programs. Ps are former students who enrolled in Ds' traditional on-campus programs for the Spring 2020 semester. Ps were required (1) to pay tuition and mandatory fees, and (2) to sign a Financial Responsibility Agreement (FRA) via an online registration portal. The fees included a student activity fee, a wellness fee, a computing and network services fee, and a security, safety, and transportation fee. Ps also prepaid housing and dining fees if they anticipated use of those services. The FRAs are two-page documents obligating students to timely pay tuition and fees and providing Ds with certain collection rights if those payments are not made. Pitt's FRA-but not Temple's-contains an integration clause stating that the FRA 'constitutes the entire agreement between the parties with respect to the matters described.' Students who enrolled in the traditional on-campus programs received in-person instruction and access to campus facilities. Midway through the semester, on March 11, 2020, then-Governor Wolf ordered a temporary closure of all non-life-sustaining businesses due to the Wuhan Flu (COVID-19). The World Health Organization declared a global pandemic. Ds closed campus buildings, canceled all on-campus student events, announced that classes would be conducted online for the remainder of the semester, and urged students not to return to campus housing. Ds did not offer any reduction in tuition or mandatory fees. Some pro-rata housing and dining refunds were given. Ps brought suit for breach of contract, or, in the alternative, unjust enrichment. Ps alleged that they paid for in-person services and education, and by switching to an online education Ds provided a materially different product. Of course, Ps paid fees for services and facilities that were not being provided. Ps claimed that 'the terms of this contract were as implied or set forth' through Ds' 'websites, academic catalogs, student handbooks, marketing materials, and other circulars, bulletins, and publications,' which described the benefits of campus life. Ps sought a pro-rata refund for the difference between in-person and online education. The District Courts found the FRAs to be fully integrated agreements that governed the parties' relationships with respect to the collection of tuition and fees and that did not require in-person instruction or services. They held that Ps also failed to state a breach of implied contract because they did not identify any specific and identifiable promise that Ds had broken. Ps appealed.
Issues
The legal issues presented in this case will be displayed here.
Holding & Decision
The court's holding and decision will be displayed here.
Legal Analysis
Legal analysis from Dean's Law Dictionary will be displayed here.
© 2007-2025 ABN Study Partner