Wards Corner Beauty Academy v. National Accrediting Commission of Career Arts & Sciences, No. 18-1290 (4th Cir. 2019)Annotate this Case
WCBA appealed the district court's dismissal of its action against NACCAS, alleging due process violations in an accreditation proceeding and seeking injunctive and declaratory relief. The Fourth Circuit held that there was insufficient evidence that WCBA was deprived of an impartial decisionmaker as a result of a Commissioner's speculative pecuniary interest so as to justify a departure from the deferential standard due to an accreditation agency; NACCAS's rules did not impose a higher standard than the general common law duty to provide an impartial decisionmaker such that a violation of those rules leads to a due process violation in this case; and WCBA failed to preserve the issue of whether it was denied due process on the theory that the Commissioners who reviewed WCBA's accreditation improperly prejudged the decision by acting as both investigators and adjudicators.