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Contracts Keyed to Blum
Rodi v. Southern New England School of Law
Citation:389 F.3d 5 (1st Cir. 2004)
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In July of 1997, Plaintiff received a recruitment letter from Dean Larkin of SNESL. The letter stated that the ABA had voted to recommend SNESL for provisional accreditation, that SNESL was highly confident of receiving the required ratifications, and that the school’s future had never been brighter. Accordingly, Plaintiff intended to take the New Jersey bar exam, and New Jersey requires bar applicants to hold law degrees from ABA-accredited institutions.
Plaintiff enrolled at SNESL that month but received a catalog from SNESL containing a statement that SNESL makes no representation to any applicant or student that the ABA will approve it before the graduation of any matriculating student. However, the ABA denied SNESL’s application for accreditation in September 1997, and Plaintiff considered transferring to an accredited school. Acting Dean Prentiss then wrote to Plaintiff to make sure he was fully informed of SNESL’s current ABA accreditation status. The letter stated that SNESL improved four areas that the ABA found deficient and that there should be “no cause for pessimism” about achieving accreditation.
Plaintiff relied on these and other representations, and he remained at SNESL. In November 1999, the ABA denied SNESL’s renewed application, and SNESL failed to appeal the denial as promised. Plaintiff completed his studies in June of 2000, but SNESL was unaccredited, and Plaintiff could not sit for the New Jersey bar. Plaintiff subsequently filed suit in June 2003.
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