Oyama v. Univ. of Hawaii, No. 13-16524 (9th Cir. 2015)Annotate this Case
Plaintiff 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.