Adler University: Student Discipline, Dismissal & Federal Court

How do student discipline and dismissal cases work at Adler University?

Adler University is a private graduate university of psychology, counseling and related professions, with its Chicago campus at 17 North Dearborn Street in the Loop, Cook County, plus a Vancouver campus and online programs. It is accredited by the Higher Learning Commission, and its Chicago Psy.D. in Clinical Psychology is accredited by the American Psychological Association. Grades, professional behavior, practicum problems and conduct largely run through one referral system, and two sentences in Adler’s own documents shape everything else: its handbook says students “cannot bring legal representation” to those committee meetings, and its complaint policy says students “must exhaust” the internal appeal “before bringing a legal claim against Adler University.”

Adler University 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 Adler University 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 Adler 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.

Grades are only part of it

Adler’s Basic Student-Trainee Competencies Policy says faculty, supervisors and administrators “have a duty and responsibility to evaluate the competence of students across multiple aspects of performance and functioning.” Concerns go first to a departmental Student Development Committee (SDC) “for initial remediation”; ongoing ones go to the Student Comprehensive Evaluation Committee (SCEC). The 2024–25 handbook for the M.A. in Clinical Mental Health Counseling shows how a professionalism concern becomes a referral: instructors rate every student each semester on a dispositions form, a rating below 3 triggers remediation or referral, and faculty “may refer students to the SCEC with recommendation of dismissal from the program.” Practicum trouble takes the same road — a student may be “referred to SCEC, removed from their site, and/or not permitted to enroll in internship,” the site-removal problem in its clinical-training form.

The committee meeting: no lawyer, no recording, no rescheduling

The Student Handbook linked from Adler’s Disclosures page is the 2023–2024 edition, and its Chicago-campus procedures are blunt. “The SDC and SCEC meetings are not legal proceedings and as such, students cannot bring legal representation.” You may bring your faculty adviser and, if you email the Director of Student Affairs “at least five business days in advance,” a staff liaison who may not answer for you unless a member asks and you agree. The meetings “cannot be re-scheduled, in the absence of extenuating circumstances”; missing an SDC meeting sends you to the SCEC, and missing an SCEC meeting means you “may be dismissed from the program.” Expect “a minimum 20-minute meeting,” no recording, and a decision letter copied to your adviser, Student Affairs, the chair and the Training Department. Failing to finish an SCEC remediation plan on time can also end the program. Adler publishes no standard of proof for these decisions.

Ten business days, and the exhaustion clause

Under the handbook, an SDC or SCEC decision may be appealed “in writing, within 10 business days of the initial decision date,” for a procedural error showing “a substantial breach of institutional processes or procedures,” substantive new information, or a decision “biased or in violation of stated student rights.” SDC appeals go to the department chair and are final; SCEC appeals go to the campus executive dean, whose decision the handbook lets you take to the Vice President of Academic Affairs.

Adler’s Office of Student Affairs, on a Complaints and Appeals page updated in March 2025, describes the route differently: appeals of “academic status, disciplinary action, or dismissal” go through the Student Complaint Form “within 10 business days of the incident or initial decision date,” and “All decisions on appeals are final.” Count from whichever date came first. The same page says students “must exhaust” this procedure before any legal claim, and lets Adler “temporarily restrict students who have been referred for a comprehensive evaluation process” from classes and training during the review and the appeal — an interim suspension in all but name.

Probation, dismissal, and no second application

Academic status, as printed in the counseling handbook, runs on a 3.0 GPA. Probation follows a second C, a single D, F, WF, NC or WNC, three or more B- grades, or a GPA below 3.0; dismissal may follow two or more of those failing grades, a third C, two semesters below 3.0, or an unmet remediation plan. Then the sentence that makes the appeal decisive: “Students who have been dismissed are ineligible to reapply to the University.” Grade appeals reach only grades of C or lower where a grading standard was not set or not followed, and the second step is due “within ten (10) calendar days” of the instructor’s response; the counseling handbook counts the same step in business days, so work to the calendar count.

The Academic Honesty Policy, republished on April 1, 2026, treats unacknowledged material “generated by artificial intelligence tools, including but not limited to ChatGPT” as plagiarism, makes misconduct “whether inadvertent or intentional” serious, and says ignorance of the policy “is not a defense.” It publishes no hearing, no standard of proof and no deadline; allegations are referred “to the appropriate person or committee on each campus.” An AI-use accusation is therefore decided through the referral route above.

Sexual misconduct: 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). Adler’s Title IX policy for the Chicago and Online campuses — the August 2020 document, re-posted in February 2026 — provides the hearing that rule calls for: the 2020 regulation requires postsecondary institutions to hold a live hearing at which each party’s advisor conducts cross-examination. The advisor “may be, but is not required to be, an attorney,” and otherwise plays “a passive role.” The standard is preponderance of the evidence, and an appeal is due “within seven (7) days,” a period the policy counts including weekends and federal holidays, to 5:00 p.m. Central time.

What a student defense lawyer can do here

Most of the value is early and quiet. It is reading Adler’s policy against what the University 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.

At Adler the work is preparation, because no lawyer may sit in an SDC or SCEC meeting: the written statement you decide whether to submit, the liaison request five business days ahead, and a remediation plan with concrete, achievable terms. And because Adler requires exhaustion, the 10-business-day appeal is the step that keeps every later option open, argued on the three published grounds.

What a lawyer cannot do is turn a campus meeting into a trial. The rules of evidence do not apply, there is no discovery, and Adler 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 Adler’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.

What to do first

1. Count ten business days from the earlier date — the incident or the decision — and file the Student Complaint Form with StudentComplaints@adler.edu; an SDC appeal goes to your program chair or director.
2. Get the handbook that governs you. The current Student Handbook is the 2026–2027 edition in Adler’s online catalog; save it, dated, with your program handbook, and compare it with the 2023–2024 text quoted here.
3. Ask in writing for the paper: the referral incident description the handbook says you will receive, any disposition ratings, and the committee members’ names.
4. Line up support. Invite your adviser and request a Student Affairs liaison at least five business days before the meeting.
5. Raise disability early. If a condition or an unmet accommodation explains what happened, it is a Section 504 and ADA question for the record now. For the wider picture, see 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.

The federal money on the line at Adler

Adler University students took on $34.3 million in federal Direct Loans in the 2025–26 award year — with 577 graduate and professional students also borrowing through Grad PLUS.

Every dollar of it rides on academic standing. A dismissal, a failed Satisfactory Academic Progress evaluation, or a mid-term withdrawal sets off federal rules that decide whether aid continues, whether money already disbursed has to go back, and — under the borrowing caps in effect since July 1, 2026 — whether a student who leaves can still finance a return. The academic fight and the financial aid fight are the same fight, and the windows are short. How those rules work: SAP appeals and academic dismissal.

On the Department’s financial responsibility test, Adler University’s most recent published composite score is 1.9 (fiscal year 2022–23) — a passing score on the –1.0-to-3.0 scale, where 1.5 and above passes. How to read that number: the federal warning signs guide.

Source: U.S. Department of Education, Federal Student Aid Data Center, Direct Loan volume by school, award year 2025–26 (cumulative through June 30, 2026). Institution-wide federal Direct Loan totals.

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:

• American Islamic College
• Aurora University
• Benedictine University
• Bexley Hall Seabury Western Theological Seminary Federation
• CAAN Academy of Nursing
• Catholic Theological Union at Chicago

Common questions about Adler student cases

How long do I have to appeal an SDC or SCEC decision at Adler?

Ten business days. The 2023–2024 handbook counts from “the initial decision date”; Adler’s Complaints and Appeals page counts from “the incident or initial decision date,” so use whichever came first. The appeal must rest on procedural error, substantive new information, or bias or a violation of stated student rights.

Can I bring a lawyer to an Adler SDC or SCEC meeting?

No. The handbook says those meetings “are not legal proceedings and as such, students cannot bring legal representation.” You may bring your faculty adviser and, with five business days’ notice, a Student Affairs liaison. A lawyer can still prepare you and your written statement, and in a Title IX case your advisor may be an attorney.

What standard of proof does Adler use?

For SDC and SCEC decisions, Adler publishes none, and its Academic Honesty Policy states none either — while adding that misconduct “whether inadvertent or intentional” is serious. Its August 2020 Title IX policy uses preponderance of the evidence, meaning more likely than not.

Can Adler keep me out of class or practicum while I am under review?

Yes. Adler’s Complaints and Appeals page lets it “temporarily restrict students who have been referred for a comprehensive evaluation process” from classes, training and university activities, and says the restriction may continue through the appeal. Ask in writing for its reason, scope and expected length.

If Adler dismisses me for grades, can I reapply later?

Not under the academic-status rules printed in the 2024–25 counseling handbook: “Students who have been dismissed are ineligible to reapply to the University.” That makes the 10-business-day appeal the decisive step. Check the 2026–2027 catalog and your program handbook for the current wording before you file.