Student Loses Religious Discrimination Suit Against Private University

In Schumacher v. Argosy Education Group, Inc., (D MN, Dec. 6, 2006), a Minnesota federal district court rejected religious discrimination claims by a Christian student who was dismissed from a graduate psychology program at Argosy University, a private college, because of his verbal impulsivity and lack of social awareness. The student alleged that the faculty was biased against him because of his evangelical Christian religious views, and particularly his views opposing homosexuality. The court rejected his argument that the school was engaged in "state action" because it acted as a "gatekeeper" for state licensing of psychologists. Absent state action, the school's decisions were not subject to federal or state constitutional limitations. As to statutory discrimination claims, the court found that there was no evidence that the student was discriminated against on the basis of religion. Instead, it found that he was dismissed for academic reasons. The court also rejected breach of contract and defamation claims.