Steinberg v. Chicago Medical School
371 N.E.2d 634 · Illinois Supreme Court · 1977
Facts
Robert Steinberg applied to Chicago Medical School, paid a fee, and was rejected. He alleged the school failed to evaluate applications based on academic criteria in its bulletin, instead using monetary contributions, and filed a class action for breach of contract, fraud, and other claims. The trial court dismissed all counts, and the appellate court partially reversed.
Issue
Can an applicant sue a medical school for breach of contract and fraud when the school allegedly failed to evaluate applications based on advertised academic criteria, instead using monetary considerations? Is this a proper class action, and what is its scope?
Holding
The court affirmed that the complaint stated causes of action for breach of contract and fraud. It reversed the appellate court's dismissal of the fraud count and its limitation of the class, allowing a broader class action. The dismissal of consumer fraud and unjust enrichment counts was affirmed.
Rule
An institution's advertised application criteria can form a binding contract upon acceptance of an application and fee. A misrepresentation of future conduct can constitute fraud if it is part of a scheme to defraud. Class actions are proper if statutory prerequisites are met, including common questions predominating, even if individual proof is needed for some claims.
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