The ABA's (D) Council on the Section of Legal Education is the organization charged with accrediting law schools. The federal government does not directly accredit institutions of higher education. The Secretary of Education approves accrediting agencies for different types of educational programs, and these accrediting bodies set independent standards for accreditation. Accreditation is important to a school for a number of reasons, not the least of which is that it allows the students of the school to receive federally-backed financial aid. In addition, the majority of states use ABA accreditation to determine whether an individual applying for admission to the Bar has satisfied the state's legal education requirement. Under ABA rules, a school may offer up to 20% of its legal program at a separate campus without this being a 'major change' requiring prior approval. If a school offers more than 20% of its program, however, this does constitute a major change, and the ABA must grant acquiescence. P applied to D to open a satellite at the Oakland campus. Under either the old or new interpretations, P's proposal constituted a major change that required ABA acquiescence. As the new interpretations of Standard 105 had not been approved, D considered P's application under the existing, more stringent requirements for a branch campus and found it lacking. P also submitted an application for a second satellite campus, this one at Grand Rapids. D again considered P's proposal using the existing interpretation of Standard 105 and again recommended that the application be denied. The Council adopted the Committee's recommendation and denied P's application. On the day P received the Council's ruling, P informed D that it was increasing its program offering at both campuses above the 20% level, despite the fact that the school had been denied acquiescence. P argued that the plain language of Rule 19 dictated that an existing accredited law school must only 'inform' the ABA of its decision to implement the major change of opening a branch location, so that a site visit could be scheduled 'within six months of the start of classes at the branch or additional location.' D replied that P's interpretation was wrong and also informed P that 'operating either of these programs without prior acquiescence of the Council would be a violation of Standard 105 and could subject the school to sanctions.' P resubmitted applications for the opening of full branch campuses at both the Oakland and Grand Rapids locations. D denied the application and asked P to appear at the show-cause hearing. P filed the instant lawsuit. P then agreed to reduce its offerings at Oakland and Grand Rapids to comply with the 20% limit on non-approved programs. Cooley further agreed not to expand the programs without D approval. At the hearing, D censored P for its 'substantial and persistent noncompliance' with ABA standards and directives and ruling that the school would be ineligible to operate branch or satellite campuses until July 31, 2006. P then claimed that D denied its common law right to due process and requested judicial review of D's decision. The district court granted summary judgment to D. P appealed.