Midwest College of Oriental Medicine (Skokie): Student Discipline, Dismissal & Federal Court

How do student discipline and dismissal cases work at MCAHM?

The Midwest College of Acupuncture and Herbal Medicine — MCAHM, formerly the Midwest College of Oriental Medicine — is a small private, for-profit acupuncture school founded in 1979 and accredited by the Accreditation Commission for Acupuncture and Herbal Medicine, with its administrative campus in Racine, Wisconsin, and a second campus and student clinic on Gross Point Road in Skokie, Cook County. Its main program awards a Bachelor of Science in Nutrition together with a Master of Science in Acupuncture and Herbal Medicine. The rule that catches students is academic: MCAHM has no academic probation. Its 2026–2029 catalog says a cumulative GPA below 2.0 “will result in a letter of dismissal, with the opportunity to petition to rescind the dismissal,” and that “The College does not have a probationary period for poor academic progress” — while its own posted progress policy describes an appeal “with one quarter of probation.”

The Midwest College of Acupuncture and Herbal Medicine is a private institution. There is no state action, so there is no constitutional due process claim, and arguing one wastes an appeal. The theory is contract: Illinois holds that a college and its students have a contractual relationship whose terms come from the catalog and the handbook — Raethz v. Aurora University, 346 Ill. App. 3d 728 (2004), restated by the Fourth District in Urso v. Bradley University, 2023 IL App (4th) 230165 — while adding that the relationship “is unique and cannot be strictly categorized or characterized in purely contractual terms.”

The limit is the standard of review, and it decides most of these cases before anyone reaches the facts. A student has a remedy for an adverse academic decision only if it was made arbitrarily, capriciously, or in bad faith. Frederick v. Northwestern University Dental School, 247 Ill. App. 3d 464 (1993), puts it bluntly — courts have been loath to review, much less overturn, academic dismissals — and Bosch v. NorthShore University Health System, 2019 IL App (1st) 190070, holds that a school which departs somewhat from its handbook still wins unless the departure was material. The federal courts in Chicago apply the same test: in Doe v. Columbia College Chicago, 933 F.3d 849 (7th Cir. 2019), the Seventh Circuit affirmed dismissal of a student’s contract claim where the college had investigated and reasoned its way to a decision, and in Gash v. Rosalind Franklin University, 117 F.4th 957 (7th Cir. 2024), it held that calling a process arbitrary or predetermined, without specific facts, is not enough. What survives is specific: in Liu v. Northwestern University, 78 F. Supp. 3d 839 (N.D. Ill. 2015), a former law student’s claim went forward where the school imposed what amounted to an integrity charge while denying her the handbook procedure for contesting one. Federal law does not care that the school is private: Title IX, Title VI and Section 504 of the Rehabilitation Act apply because it takes federal funds, and the ADA applies to it as a place of public accommodation.

A federal claim arising at the Midwest College of Acupuncture and Herbal Medicine’s Skokie campus is filed in the United States District Court for the Northern District of Illinois — Cook County sits in its Eastern Division under 28 U.S.C. § 93(a), and the statute fixes the places of holding court for that division at Chicago and Wheaton. I am a member of the general bar of that court, admitted on my Florida license under its Local Rule 83.10, which opens the general bar to an attorney in good standing before the highest court of any state. That means a Title IX, Section 504 or ADA complaint for an MCAHM student is one I file and litigate under my own name, with no pro hac vice motion. The Northern District abrogated its local-counsel designation rule in July 2023, so a member of its bar with no office in the district no longer has to designate local counsel. One limit, stated plainly: the court keeps a separate trial bar, and under Local Rule 83.12 a general-bar member who is not on it — that is me — appears alone in everything except testimonial proceedings, meaning evidentiary hearings and trial, where a trial-bar member must sit as advisor unless the judge grants the rule’s narrow waiver.

Which documents govern

The 2026–2029 catalog, posted in September 2026, is the current rulebook for both campuses; it still lists a Skokie campus director, clinic director and librarian, and the college’s clinic page gives Skokie hours on Mondays and Thursdays. The catalog sends conduct and complaint questions to “the grievance policy delineated in the Student Handbook,” but the only handbook on the college’s website is the Fall 2021–2022 edition, from the Midwest College of Oriental Medicine era. Two other documents matter: a Satisfactory Academic Progress policy posted in 2024, and a Title IX policy reviewed February 24, 2026. Read them together, and expect gaps: the catalog itself gives the maximum time to finish as 60 and 72 months in one place and 45 and 54 months in another.

Academic standing: a dismissal letter, not probation

The catalog requires a cumulative GPA of 2.5; below that, academic counseling is required. Below 2.0, the dismissal letter issues. Federal aid recipients must also pass two-thirds of the class hours attempted each year, and the catalog says there is “no probationary period” for that either. Students dismissed for unsatisfactory progress “may petition for reinstatement”; the petition “should indicate the cause of unsatisfactory academic progress,” and an academic committee recommends on reinstatement and aid eligibility. No deadline for the petition is published. The 2024 progress policy goes further than the catalog: it describes a petition “to appeal dismissal with one quarter of probation,” after which, if the GPA is still below 2.0, “the dismissal will be final.” A petition should ask for exactly that quarter. See academic dismissal and SAP appeals.

The routes to that letter are mechanical. A missed or failed midterm or final must be passed on a different version within two weeks, with retakes capped at 70%; anything still incomplete by the second week of the next quarter becomes an F and the class must be repeated. Attendance must reach 80%, which the catalog translates as two absences in a twelve-week quarter, and a student who misses more than two sessions in all of their classes in a quarter without making them up is “eligible for dismissal from the program.”

Conduct: suspension of up to two weeks, or dismissal

Under the catalog’s Conduct / Right of Dismissal provision, a student may be suspended “not to exceed two weeks” or dismissed for conduct that disrupts teaching or administration or interferes with others’ rights. The examples include disrespect, dishonesty, failing to follow internship policies or school officials’ directions, abuse, theft, “meeting the U.S. Department of Education definition of sexual harassment,” and teaching or practicing acupuncture or herbal medicine before graduation and licensure. The catalog adds a promise: “Students can request a hearing, by following the College’s grievance policy, before any final action is taken.” More on conduct code defense is on its own page.

The public 2021–2022 handbook supplies the mechanics, and they are fast. An administrator’s letter states the problem, the time frame and the people involved, and the proposed action is held until the day after your deadline to start the grievance process — unless you agree with it. That first request is due “within two days (excluding Sundays and holidays the College is closed)” of receiving the letter, so Saturdays count. The ladder then runs from an informal meeting, which the handbook aims to hold within one week, to a mediation meeting before another administrator, where any of the three participants may question each other and witnesses who gave written statements; you then have two days to accept the arbitrator’s memo or request a grievance hearing. A committee of an administrator, a faculty member and a student representative reviews the record “within 60 days” of the request and gives a written decision, and you have two days to take it to the Board of Advisors, whose decision is final. After that the handbook points only to complaints to the accreditor and the state agencies. The catalog now lets every meeting be held in person or by Zoom, at the student’s choice. Neither document states a standard of proof.

The clinic is where many problems surface, and the handbook is blunt about it: “The internship supervisor has the right to not accept students into their clinic without explanation.” If you are kept out of clinic shifts, put the reasons you were given in writing at once; see clinical removal.

Sexual misconduct: a 2026 policy with a live hearing

For sexual misconduct, the federal rule is the 2020 Title IX regulation: the 2024 rule was vacated nationwide on January 9, 2025, in Tennessee v. Cardona, and on September 29, 2026 the Department of Education formally repealed it and restored the pre-2024 text (91 Fed. Reg. 61,308). MCAHM’s Title IX policy, reviewed February 24, 2026, follows that model. The College President is the Title IX Coordinator, an advisory board member is the deputy, and a Confidential Advisor is named. A formal complaint brings written notice stating that the respondent is presumed not responsible and that each party may have an advisor “who may be, but is not required to be, an attorney.” The college “will endeavor” to finish its investigation in sixty days; each side gets ten days to respond to the evidence before the report is finalized — the policy does not say calendar or business — and the final report ten days before the hearing. The 2020 regulation requires postsecondary institutions to hold a live hearing at which each party’s advisor conducts cross-examination. MCAHM’s policy confirms it: at the live hearing, questioning is done “directly, orally, and in real-time” by each party’s advisor, never by the party. The standard is preponderance of the evidence; the written determination is due within seven business days of the hearing; and an appeal, signed and in writing, goes to the Title IX Coordinator “within ten calendar days” on procedural irregularity, new evidence, or bias. The other side gets ten calendar days to respond, and the Appeal Officer’s decision is final. More on Title IX hearings and cross-examination is on its own page.

What a student defense lawyer can do here

Most of the value is early and quiet. It is reading MCAHM’s policy against what it actually did and finding the gap; writing the response or the appeal so it argues the grounds the policy recognizes rather than the ones that feel most unfair; preserving the federal issues — Title IX, Section 504 and the ADA, FERPA — so they are in the record if the case ever leaves campus; and identifying comparators, because a sanction far outside what similar cases drew is one of the few arguments that reliably moves a decision-maker.

Two moves are specific to MCAHM. First, on a conduct letter, the written request for review should go in within the two-day window, because under the handbook it keeps the proposed action from taking effect, and it should say expressly that you do not agree with that action. Second, on an academic dismissal, the petition should do what the policy asks — name the cause of the poor progress and what has changed — and ask for the one quarter of probation the 2024 progress policy describes, quoting it, since the catalog says probation does not exist.

What a lawyer cannot do is turn a campus process into a trial. The rules of evidence do not apply, there is no discovery, and MCAHM decides its own case at first instance. That is why the written record built during the campus process is the whole ballgame: by the time a court looks at it, the record is closed.

The one Illinois statute that gives you procedure

Illinois has no general statute setting notice periods, hearing formats, standards of proof or appeal rights for college students. The Illinois School Code, 105 ILCS 5, has a detailed suspension and expulsion scheme, and it applies to elementary and secondary schools, not here. The exception is the Preventing Sexual Violence in Higher Education Act, 110 ILCS 155, and it is a real one. It reaches every higher education institution in the state — public universities, community colleges, and private not-for-profit and for-profit institutions alike — and it requires timely written notice of the allegations to all parties, an investigation that is adequate, reliable and impartial, written notice of the outcome, and appeal rights. It requires the school to make confidential advisors available, trained to a statutory standard and kept separate from the people deciding the case. Both parties are entitled to an advisor of their choice, and that advisor may be an attorney — although the institution may limit how far an attorney-advisor participates in a hearing, which is why MCAHM’s own rule on that, set out above, still governs what your lawyer may do in the room. The standard of proof is preponderance of the evidence, applied the same way to both sides.

MCAHM’s 2026 Title IX policy lets an attorney serve as advisor and conduct the cross-examination, though the college “may restrict the extent to which the advisor may participate” if the limits apply to both sides. Outside Title IX the public record is thin and older: the 2021–2022 handbook says that in sexual harassment and discrimination grievance hearings the parties “may not be represented by counsel,” and it is silent on advisors in ordinary conduct cases.

What to do first

1. Answer a conduct letter within two days. Count Saturdays; only Sundays and closure holidays are excluded. Ask for review in writing and say you do not agree with the proposed action.
2. Ask for the current Student Handbook. The public edition is from 2021–2022. Email the Dean of Students for the version in force when the events happened, and keep the reply.
3. Petition promptly on a dismissal letter. No deadline is published, so ask in writing for the date by which the academic committee needs your petition, and ask for the one quarter of probation in the 2024 policy.
4. Assemble your own records. Attendance logs, exam and retake dates, clinic evaluations and every email with an instructor or supervisor.
5. Raise disability early. The catalog routes individual arrangements through the admissions office; if a condition explains the grades or attendance, that is a Section 504 and ADA question for the record now. See also the Illinois student defense hub.

One honest caveat about geography. Illinois has three federal districts. I am admitted to two of them, the Northern and the Southern. A federal claim arising at a school in Springfield, Peoria, Champaign-Urbana or the Quad Cities falls in the Central District; I am not a member of that bar, and those matters I handle with local counsel in that district or by pro hac vice admission. Appeals from the Northern District go to the Seventh Circuit, which keeps its own bar; my appellate admission is in the Eleventh. I say so before a retainer rather than after.

Where I am licensed. I am licensed to practice law in Florida. I am admitted to the bars of the U.S. District Courts for the Southern, Middle and Northern Districts of Florida, the District of Colorado, the Northern and Southern Districts of Illinois, the District of Nebraska, the District of New Mexico, and the Western District of Wisconsin, and the U.S. Court of Appeals for the Eleventh Circuit. Federal court admission is not a license to practice the law of the state in which the court sits. I am not licensed in Illinois and do not advise on Illinois state law or appear in Illinois state court.

Other schools in the Northern District of Illinois

Every school writes its own dismissal, appeal and conduct rules, and the deadlines are rarely the same from one campus to the next. These pages set out the procedure at other schools in the Northern District of Illinois:

• Midwestern Career College
• Midwestern University-Downers Grove
• Moody Bible Institute
• Morrison Institute of Technology
• National Louis University
• National University of Health Sciences

Common questions about MCAHM student cases

Does MCAHM put students on academic probation?

Not according to its 2026–2029 catalog, which says a cumulative GPA below 2.0 “will result in a letter of dismissal, with the opportunity to petition to rescind the dismissal,” and that the college has no probationary period. Its 2024 progress policy, though, describes a petition “to appeal dismissal with one quarter of probation.” Ask for that quarter in the petition, and explain the cause of the low GPA.

How long do I have to respond to a conduct letter at MCAHM?

Two days. The 2021–2022 handbook, the only edition the college posts, requires the first request for review “within two days (excluding Sundays and holidays the College is closed)” of receiving the letter. Unless you agree with the proposed action, it is held until the day after that deadline, so a timely written request matters. Ask the Dean of Students for the current handbook in the same email.

Can I bring a lawyer to an MCAHM hearing?

In a Title IX case, yes: the 2026 policy lets each party choose an advisor “who may be, but is not required to be, an attorney,” and advisors conduct the cross-examination at the live hearing. Outside Title IX the public handbook is older and narrower — it bars counsel in sexual harassment and discrimination grievance hearings and says nothing about advisors in ordinary conduct cases — so ask in writing before any meeting.

Is the Midwest College of Oriental Medicine still open in Skokie?

The college now operates as the Midwest College of Acupuncture and Herbal Medicine. Its 2026–2029 catalog lists a Skokie campus at 8950 Gross Point Road with its own campus director, clinic director and librarian, and its clinic page lists Skokie clinic hours. The shorter acupuncture-only program is listed as suspended; the acupuncture and herbal medicine program continues.

How long do I have to appeal a Title IX decision at MCAHM?

Ten calendar days. The 2026 Title IX policy requires a signed, written appeal to the Title IX Coordinator within ten calendar days of the determination, limited to procedural irregularity, new evidence, or bias or conflict of interest that affected the outcome. The other party gets ten calendar days to respond, and the Appeal Officer’s written decision is final.