Morehouse College Inc. v. McGaha

The plaintiff was required to mitigate his damages by returning to school and obtaining a college degree after the defending college expelled him without abiding by the hearing procedures in its student handbook.

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After Antonio McGaha was expelled from Morehouse College, a jury awarded him $698,500 in damages on a breach of contract claim based on Morehouse’s failure to follow proper procedure. The trial court denied Morehouse’s motion for a new trial, and Morehouse appeals, arguing that: 1 the trial court erred in allowing testimony on future lost wages, a measure of damages not recoverable in a contract action; 2 the verdict is excessive; and 3 the trial court erred in allowing McGaha to introduce irrelevant evidence about disputed credit hours on his transcript, which prejudiced the jury against Morehouse. For reasons that follow, we affirm in part and reverse in part. The evidence, viewed in a light most favorable to the verdict,1 shows that McGaha became a student at Morehouse in the fall of 1997. He paid his tuition with student loans. During his freshman year, McGaha applied to participate in an exchange program called “Biosphere 2,” which took place in Arizona and was sponsored by Columbia University. He was accepted and began the semester-long program in September 1998.

Dr. Anne Watts served as the liaison between Morehouse and the Biosphere 2 program. McGaha understood from her that Morehouse would send his financial aid check to him in Arizona, he would take the check to the comptroller of the Biosphere 2 program, and his expenses would be deducted from the check. In fact, McGaha received a check from Morehouse made payable to the Biosphere 2 program for $8,905.52. He took the check to the Biosphere 2 comptroller’s office. The comptroller’s office returned approximately $7,000 to him. McGaha did not find this unusual, as Morehouse had refunded approximately $4,000 to him in previous semesters and because he had applied for a scholarship with the Biosphere 2 program. Thus, McGaha used the $7,000 to repay loans he had previously received.

Morehouse College Inc. v. McGaha

The plaintiff was required to mitigate his damages by returning to school and obtaining a college degree after the defending college expelled him without abiding by the hearing procedures in its student handbook.

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