Yale Doesn’t Owe Students Refunds for Canceling In-Person Classes Over COVID-19: Court

Students walk on the campus of Yale University in New Haven, Conn., in a file photograph. Yana Paskova/Getty Images

Yale University does not need to give refunds to students after canceling in-person classes in early 2020, a federal appeals court ruled on Aug. 7.

Yale was accused of providing inferior education than it promised, but the university had the discretion to respond to the COVID-19 pandemic by transitioning completely to online classes without issuing tuition refunds, a panel of the U.S. Court of Appeals for the Second Circuit said.

Jonathan Michel, a sophomore at Yale at the time, paid tuition to the university for the spring of 2020, which started normally but, after nine weeks, was transitioned from in-person to remote over COVID-19.

Yale refunded students’ room and board charges for the period of time the campus was closed, but did not provide tuition repayment, prompting a lawsuit from Michel.

“Plaintiff and the putative class contracted and paid for the full experience of academic life on defendant’s campus and remote online learning cannot provide the same value as in-person education,” stated Michel’s suit, which was aimed at becoming a class-action case.

“Plaintiff brings this suit because plaintiff and the class members did not receive the full value of the services for which they paid. They have lost the benefit of their bargain and/or suffered out-of-pocket loss and are entitled to recover compensatory damages, trebling where permitted, and attorneys’ fees and costs,” he added later.

Yale argued the decision to close its campus was well-reasoned and that Michel failed to identify a breach of any contract provision.

U.S. District Judge Janet C. Hall sided with Yale, noting Yale’s regulations include the ability to temporarily suspend university operations.

The appeals court panel upheld that finding.

“Michel and Yale had a contractual relationship that was governed in relevant part by a ‘Temporary Suspension Provision’ in Yale’s Undergraduate Regulations. That provision, which operated as a force majeure clause, allowed Yale to switch to online-only classes during the Spring 2020 semester in response to the global pandemic without issuing tuition refunds,” U.S. Circuit Judge Beth Robinson wrote for the unanimous panel.

“Because Michel’s quasi-contract claims arise from matters covered by the parties’ implied contract, including the Temporary Suspension Provision, those claims fail under Connecticut law,” she added later.

Even if Yale promised a typical semester would feature in-person classes and services, then the provision covers the school’s suspension of in-person classes, according to the ruling.

Robinson was joined by U.S. Circuit Judges Debra Ann Livingston and Reena Raggi.

The ruling was issued days after another federal court ordered Johns Hopkins University to pay $2 million for canceling in-person classes during the same period of time. That order came after the Maryland school settled after losing its effort to dismiss the case.