The Fourth Appellate District reversed a judgment. The court held that the University of California satisfied a graduate student’s due process rights by providing notice of the student’s academic deficiencies, their consequences, and an opportunity to improve before exercising professional judgment to deny the student advancement to a Ph.D. program.
Shane Lachtman entered the graduate program in the History Department of the University of California, Irvine (UCI). After Lachtman’s first year, the History Department advised him not to continue in the Ph.D program. The Department offered Lachtman the options of withdrawing or pursuing a terminal master’s degree in lieu of a Ph.D. Lachtman responded that he wanted to remain in the Ph.D. program. The History Department maintained its recommendation, but offered Lachtman the opportunity to pursue a Ph.D. if he undertook certain steps to be re-considered as a Ph.D. candidate. Lachtman refused to agree to all of the conditions.
