Chicago Theological Seminary: Student Discipline, Dismissal & Federal Court

How do student discipline and dismissal cases work at Chicago Theological Seminary?

Chicago Theological Seminary is a private seminary affiliated with the United Church of Christ, founded in 1855 and accredited by the Association of Theological Schools and the Higher Learning Commission for the MDiv, MA (Religious Studies), STM, DMin and PhD; it reported 189 students to ATS in fall 2025. It is also a school in transition. CTS stopped admitting new degree students in April 2026, left its building at 1407 E. 60th Street in Chicago, Cook County, in September 2026, and now operates fully remotely from a Chicago post office box. On September 29, 2026 it announced a proposed affiliation with Yale Divinity School under which it will offer its degree programs through 2026–27, graduate or transfer remaining students to approved teach-out schools in 2027–28, and, subject to accreditor and regulatory approval, later become a continuing-education institute. Its rules contain one provision students rarely find in a seminary handbook: a student facing non-academic dismissal may take it to a hearing at which the student “shall have the right to be represented by counsel, to present evidence and to confront adverse witnesses.”

Chicago Theological Seminary 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. Which federal statutes reach Chicago Theological Seminary depends on facts worth confirming early — whether it receives federal financial assistance, and, for a religiously controlled institution, whether it claims the religious exemptions some of those statutes allow.

A federal claim arising at Chicago Theological Seminary 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 a Chicago Theological Seminary 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.

Non-academic dismissal goes to a hearing — with counsel

Section VI of the 2026–2027 Student Handbook (revised August 2026) governs conduct “disruptive to the educational process” and violations of seminary policy. Concerns and evidence go to the Dean of Students for an initial assessment, followed where possible by informal meetings at which you may bring “a supportive person.” If the matter is not resolved, the Dean of Students reports with recommendations to the President, and you receive a copy of the report. The President decides probation, suspension or dismissal.

Dismissal opens the strongest procedure in the handbook. You may withdraw voluntarily; if you do not, you may appeal to the Administrative Council, which decides “after a hearing,” with the President voting only to break a tie and a student ombudsperson of your choosing allowed to take part without a vote. At that hearing you have the right to counsel, to present evidence and to confront adverse witnesses. Counsel and the ombudsperson leave before the deciding vote, taken in executive session, and you receive a written report of the proceedings and the decision. A further appeal goes, by written petition filed with the Dean of Students, to the Academic and Student Affairs Committee of the Board of Trustees, whose decision “shall be final.” Two gaps matter: the handbook publishes no deadline for either appeal, and no standard of proof for non-academic discipline. Probation and suspension carry no stated hearing at all. See conduct code defense.

Plagiarism and AI: two weeks to answer, probation until graduation

CTS’s AI rule is short: “Students must receive permission from faculty to use AI to complete their course assignments.” Each syllabus sets the generative-AI policy, and whatever it says, using a generator “without proper attribution violates academic integrity and will be treated as plagiarism.” The handbook adds a warning worth remembering if you are flagged: CTS’s detection software “may sometimes flag text that is improved by assistive AI” such as grammar tools, which is why it tells students to consult the instructor first. If your draft history shows a grammar tool rather than a generator, that distinction is the heart of the defense — see AI-use accusations.

The procedure (Section IV) starts with the professor notifying the Academic Dean and a meeting with the Dean. Minor, apparently unintentional cases may be resolved directly with the Dean’s concurrence. Otherwise a formal charge is given to you in writing, and the Dean invites a written statement “within two weeks of receiving the charge,” including any exculpatory evidence — the handbook does not say whether those are calendar or school weeks, so count calendar days. You may bring “another student or staff person” for clarification. The faculty decide in an executive session of the Academic Council, and penalties run from failing the course (recorded as “Withdrawn/Failure”) to a leave for a stated period or “permanent separation.” One consequence is easy to miss: “Students permitted to continue studies will be maintained on academic probation until graduation.” The Dean gives the rationale in writing, and “Appeals follow the procedures described in non-academic discipline” — which, for a separation, means the Administrative Council hearing described above.

Probation, the early academic review, and separation

Every program requires a cumulative 3.0 to graduate. A weak term brings a warning; a cumulative GPA below 3.0 brings academic probation at the start of the next semester, and a student who does not rise above 3.0 within two successive semesters on probation “may be separated from the Seminary.” Two consecutive terms without registering, and without an approved leave, can lead to separation too, and the seminary may “take the initiative” to place a student on leave. Separated students may reapply after a year, must “show due cause,” and return on probation.

The provision to watch is the Academic Review. The faculty review every MA and MDiv student after four to eight courses, and a student whose performance is substandard, or about whom there are “substantial non-academic performance concerns,” may be separated. No procedure, notice, hearing or appeal is attached. If a separation rests on non-academic concerns, ask in writing why the Section VI procedure — with its hearing and counsel — does not apply. The graduate program dismissal page covers how these reviews are usually challenged.

Discrimination, harassment and Title IX: two versions of the rules

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). CTS publishes its Policy Against Discrimination and Harassment twice, and the two texts differ. Both send a formal complaint to an Investigation Team drawn from a standing Anti-Discrimination/Anti-Harassment Task Force, aim to finish within 60 days (unit unstated), apply the “preponderance of the evidence” standard, let the seminary suspend an accused person or impose other interim measures pending the outcome, and send findings about a student into the non-academic discipline process, where sanctions can include “mandatory psychiatric assessment and/or treatment” and dismissal. But the standalone 2023 policy linked from CTS’s Policies page promises “an advisor of their choice at any related meeting or proceeding” and says CTS “will provide an advisor at no cost for the purposes of cross-examination at the hearing” — consistent with the 2020 regulation, which requires postsecondary institutions to hold a live hearing at which each party’s advisor conducts cross-examination. The 2026–27 handbook’s version drops that sentence. If you are a party, ask the Title IX Coordinator in writing which text governs, and hold CTS to the advisor and hearing it has published. See Title IX hearings and cross-examination.

What a student defense lawyer can do here

Most of the value is early and quiet. It is reading CTS’s handbook against what the seminary actually did and finding the gap; writing the response or the appeal so it argues the grounds the handbook 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 the seminary; 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 CTS, two moves stand out. First, if dismissal is on the table, use the Administrative Council hearing: it is the one stage where the handbook expressly lets a lawyer represent you, present evidence and confront witnesses, and it should be prepared like one. Second, timing. With degree programs ending after 2026–27, a semester lost to probation, an unresolved incomplete or a separation is harder to recover than it would have been a year ago. Graduating students must resolve every incomplete by January 15 of the graduation year; a four-week extension may be granted only in exceptional circumstances. Get your individualized completion plan in writing.

What a lawyer cannot do is turn a seminary process into a trial. The rules of evidence do not apply, there is no discovery, and the school decides its own case at first instance. That is exactly 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 CTS’s own rules on that, set out above, still govern 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. Ask for the deadline in writing. CTS publishes no appeal window for discipline, dismissal or plagiarism findings. Appeal promptly and ask the Dean of Students or Academic Dean to confirm, in writing, that your appeal is timely.
2. Save the 2026–2027 Student Handbook, the 2023 harassment policy, and the Yale affiliation announcement and FAQ with dates visible. They are CTS’s own written statements of the rules and of what it says it will do for enrolled students.
3. Answer a plagiarism charge within two weeks, in writing, with drafts, version history and any record of instructor permission for AI tools.
4. Request your records. Under Section V, the Registrar must give access “in 45 days or less” after a written request (the handbook does not say calendar or business days); include any academic review or candidacy documents.
5. Raise any disability now. Requests go to the Director of Student Formation & Outreach, with documentation to the Registrar; a condition that explains the performance is a Section 504 and ADA question for the record. Other schools are on 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:

• Chicago-Kent College of Law, Illinois Institute of Technology
• Columbia College Chicago
• Concordia University Chicago
• DePaul University
• DeVry University (Illinois)
• Dominican University

Common questions about Chicago Theological Seminary student cases

How long do I have to appeal a CTS discipline decision?

The handbook does not say. A dismissal may be appealed to the Administrative Council, and its decision to the Board’s Academic and Student Affairs Committee by written petition filed with the Dean of Students, but neither step carries a published deadline; plagiarism findings follow the same route. Appeal promptly, in writing, and ask the seminary to confirm that your appeal is timely — especially now that degree programs end after 2026–27.

Can I bring a lawyer to a CTS dismissal hearing?

Yes. A student appealing a non-academic dismissal to the Administrative Council “shall have the right to be represented by counsel, to present evidence and to confront adverse witnesses,” though counsel leaves before the deciding vote. Earlier stages are more limited: a “supportive person” at informal meetings with the Dean of Students, and another student or staff person for clarification in a plagiarism case.

What standard of proof does Chicago Theological Seminary use?

For discrimination and harassment, including Title IX matters, preponderance of the evidence — “whether it is more likely than not that the accused violated this policy.” The handbook states no standard for non-academic discipline, the plagiarism procedure or the academic review. If your case is in one of those tracks, ask in writing which standard will be applied before the decision is made.

Can CTS separate me after the early academic review?

It can. The faculty review MA and MDiv students after four to eight courses, and a student with substandard performance or “substantial non-academic performance concerns” may be separated. The handbook attaches no notice, hearing or appeal to that review. If the concern is non-academic, ask in writing why the Section VI procedure, with its hearing and right to counsel, does not apply.

What happens to my degree now that CTS is ending its degree programs?

CTS says it will offer its current degree programs through 2026–27, with a spring 2027 graduation, then graduate remaining students or transfer them to approved teach-out partner schools in 2027–28; PhD students get dissertation support through 2027–28. You will not move into Yale Divinity School’s degree programs. Ask for your individualized completion plan in writing and keep it.