State v. Minnesota School of Business, Inc.Annotate this Case
In this case against two for-profit universities (the Schools) alleging that the Schools violated the Minnesota Consumer Fraud Act (MCFA), Minn. Stat. 325F.69, and the Uniform Deceptive Trade Practices Act (DTPA), Minn. Stat. 325D.44, the Supreme Court held that the Attorney General proved that a causal nexus was established between the Schools' fraudulent statements and the harm suffered by students.
At issue was whether the Attorney General established a causal nexus between the Schools' statements misleading prospective students about the value of criminal justice degrees offered by the Schools and the harm suffered by students who entered the Schools' criminal justice program. During trial, fifteen students who had enrolled in the criminal justice program testified. The district court ultimately issued an injunction and ordered equitable restitution requiring the Schools to disgorge the tuition collected from the criminal justice program students. The court of appeals upheld the restitution order for the students who testified at trial but reversed the order as to nontestifying students. The Supreme Court reversed in part, holding (1) the Attorney General established a causal nexus between the Schools' misleading statements and the harm suffered by the non testifying students; and (2) the equitable restitution process ordered by the district court was proper.