Oyama v. Univ. of Hawaii, No. 13-16524 (9th Cir. 2015)
Annotate this CasePlaintiff filed suit against the University and university officials alleging violations of the First Amendment and the Due Process Clause of the Fourteenth Amendment after the University denied his application to become a student teacher. The court held that, in the context of a public university’s professional certification program, the university may evaluate the student’s speech, made in the course of the program, in determining the student’s eligibility for certification without offending the First Amendment under certain circumstances. In this case, the court concluded that the University did not violate plaintiff's First Amendment rights because its decision related directly to defined and established professional standards, was narrowly tailored to serve the University’s core mission of evaluating plaintiff’s suitability for teaching, and reflected reasonable professional judgment. Further, because the University provided adequate procedural protections in denying plaintiff’s application, neither it nor its agents violated plaintiff’s procedural due process rights. Accordingly, the court affirmed the district court's grant of summary judgment to the University.
Court Description: Civil Rights. The panel affirmed the district court’s summary judgment in an action brought by a secondary education candidate alleging that the University of Hawaii’s denial of his application to become a student teacher on the basis of his speech violated his First Amendment and due process rights. The panel held that in the context of a public university’s professional certification program, the university may evaluate a student’s speech, made in the course of the program, in determining the student’s eligibility for certification without offending the First Amendment under certain circumstances. In this case, because the University of Hawaii’s decision to deny plaintiff’s student teaching application directly related to defined and established professional standards, was narrowly tailored to serve the University’s core mission of evaluating plaintiff’s suitability for teaching, and reflected reasonable professional judgment, the University did not violate plaintiff’s First Amendment rights. In addition, because the University granted plaintiff adequate procedural protections in denying his student teaching application, it did not violate plaintiff’s due process rights. OYAMA V. UNIVERSITY OF HAWAII 3
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