Erikson Institute: Student Discipline, Dismissal & Federal Court

How do student discipline and dismissal cases work at Erikson Institute?

Erikson Institute is a private graduate school of child development, early childhood education and social work at 451 North LaSalle Street in Chicago, Cook County. The Higher Learning Commission accredits it for master’s degrees and certificates; its Master of Social Work is accredited by the Council on Social Work Education, and its teacher-licensure master’s is approved by the Illinois State Board of Education. Its rules are short and final. A master’s student who earns a single F is dismissed, the appeal is due within five business days to one official who reviews it “at their discretion,” and the handbook says its grievance, appeal and disciplinary procedures “do not afford students any contractual rights.”

Erikson Institute 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 Erikson Institute 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 Erikson 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.

One F, or a third C: dismissal

The Student Handbook 2025–26 sets master’s standing by grades as well as GPA. Good standing means a cumulative GPA of at least 3.0, no more than one grade of C+, C or C-, and no D or F. A second C-range grade brings Academic Warning. A GPA below 3.0, or a D in a required course, brings probation, which generally lasts one term including summer; you must meet your program director before the next term and may not begin an internship until you are back in good standing or on warning with a 3.0. MSW students on probation may not enter practicum at all. Dismissal follows a third C+, C or C-, a second D, any combination of three C-range or D grades, or an F — and certificate students are dismissed at the second C-range grade.

The appeal is one letter to one person. “Dismissed students may appeal in writing to the Vice President for Academic Affairs/Chief Academic Officer within five business days of receiving notice.” The Vice President or a designee reviews it “at their discretion, and the decision is final.” A registration hold goes on at dismissal and comes off only if the appeal succeeds or you are readmitted, in which case you return on probation. For an academic dismissal at Erikson, everything has to be in that first letter.

Academic integrity: AI counts unless you asked first

Erikson’s plagiarism definition covers using AI tools for coursework “without first; 1) confirming with each instructor that AI tools are permitted” and then citing what the tool produced. The faculty member has initial jurisdiction, judging the case on the course materials, “detection-related resources and reports available to them (i.e., Turnitin and other software detection tools), and their professional judgment,” and meets you “either alone or with an observer.” An agreed outcome is recorded in a signed “letter of understanding.” If you do not agree, you get written notice and the Dean of Students investigates, with discretion to convene an advisory committee. No standard of proof is published.

From the first notice, you may not change your registration in the course or withdraw from Erikson, you may be “immediately suspended until a formal investigation is completed,” and no degree issues while the charge is pending. The appeal goes to the Vice President for Academic Affairs “within 10 business days of the date that the student receives the written notification of resolution,” limited to procedural error, misinterpretation of policy, or a clear mismatch between finding and sanction — “An appeal is not an evidentiary hearing or a reconsideration of the evidence.” One more feature: the faculty member may appeal too, if they disagree with the decision or the sanction. That makes an AI-use accusation a written case from the first meeting.

Conduct: no hearing, no confrontation, no appeal

Other misconduct goes to the Dean of Students, who interviews you and makes an initial determination. If you dispute it, the Vice President for Academic Affairs chooses either an administrative review by an administrator or an outside investigator, or an ad hoc committee of three. Either way, the review is “not an evidentiary hearing, and no witness or party to the complaint has the right to personally confront other witnesses/parties or to question them directly.” “Attorney involvement in interviews or in the administrative investigative process may be permitted at the discretion of Erikson.” The Vice President’s decision “is final.” The handbook publishes no time limits and no standard of proof, and reserves the right to “fashion a new procedure” for a particular case — the conduct process at its most discretionary.

Professional expectations are policed the same way. If a student cannot meet them, Erikson may steer the internship, bar it until a plan is completed, or “remove the student from an internship that they have already begun,” and a student whose condition cannot be reasonably accommodated may be dismissed — which makes the accommodation request part of the defense.

Sexual misconduct: an investigator decides

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). Erikson’s posted Title IX policy, linked from its consumer-information page, is dated April 2024 and describes no hearing: an investigator finds the facts and decides responsibility by a preponderance of the evidence, and the Dean of Students sets a student’s sanction. Your advisor may be an attorney, but the role is “non-participatory” — the advisor “may not speak for the Complainant or Respondent nor draft any statements on their behalf.” An appeal goes to appeals@erikson.edu within five business days of receiving the final report or the sanctions notice, whichever is later, and a respondent may not withdraw while the case is pending. With the 2020 regulation now the federal rule, ask the Title IX Coordinator in writing, at the start, which procedure will govern your case.

What a student defense lawyer can do here

Most of the value is early and quiet. It is reading Erikson’s policy against what the Institute 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 Erikson two things matter most. A dismissal appeal is read once, by one person, with no further review, so it has to carry the whole case — the grades, the circumstances, the plan — in five business days. And in an integrity case, nothing should be signed until the policy and the evidence have been read: a letter of understanding is a signed resolution, and the appeal that follows a formal finding reviews procedure, not the evidence. Because the handbook disclaims contractual rights and lets Erikson adapt its procedures case by case, the record you build is the only fixed point.

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 the Institute 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 Erikson’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. Diary the deadline in business days: five for a dismissal appeal, ten for an academic-dishonesty appeal, five for a Title IX appeal, each from the day you receive the notice.
2. Save the documents. Download the Student Handbook 2025–26, your Program Book and the Title IX policy, dated, before anything is revised.
3. Ask in writing for the evidence — any Turnitin or detection report, the faculty member’s notice, and the Dean of Students’ memorandum or investigation report.
4. Do not sign a letter of understanding or written agreement until you know what you are admitting and what sanction follows.
5. Raise disability early. If a condition or an unmet accommodation explains what happened, it is a Section 504 and ADA question to put in 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 Erikson Institute

Erikson Institute students took on $3.0 million in federal Direct Loans in the 2025–26 award year — with 51 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, Erikson Institute’s most recent published composite score is 2.9 (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:

• Fox College
• Garrett-Evangelical Theological Seminary
• Generations College
• Governors State University
• Hebrew Theological College
• Illinois College of Optometry

Common questions about Erikson Institute student cases

How long do I have to appeal a dismissal at Erikson?

Five business days from receiving notice, in writing, to the Vice President for Academic Affairs/Chief Academic Officer. The Vice President or a designee reviews the appeal “at their discretion, and the decision is final.” A registration hold stays on unless the appeal succeeds or you are readmitted, so the first letter has to carry the whole case.

Can I appeal a conduct decision at Erikson?

The handbook publishes no appeal. After the Dean of Students’ initial determination, a disputed case goes to an administrative or committee review chosen by the Vice President for Academic Affairs, and “The decision of the Vice President for Academic Affairs/Chief Academic Officer or delegate is final.” The review is not an evidentiary hearing, and no one may question witnesses directly.

Can I bring a lawyer to an Erikson disciplinary meeting?

Only if Erikson agrees: the handbook says attorney involvement in interviews or the review process “may be permitted at the discretion of Erikson.” In a Title IX case, your advisor may be an attorney but cannot speak for you or draft your statements. A lawyer can always prepare you and your written submissions.

Does using ChatGPT count as plagiarism at Erikson?

It can. The handbook treats using AI tools for coursework without first confirming with each instructor that they are permitted, and properly citing what the tool produced, as plagiarism. Faculty may rely on Turnitin and other detection software together with their own judgment, so ask for any report in writing.

Can I withdraw from Erikson while an integrity charge is pending?

No. Once you receive notice of an academic-integrity concern, you may not change your registration in that course or withdraw from the Institute, and no degree or certificate issues while the charge is pending. Erikson also says it can pursue a case after a student leaves or graduates, including by rescinding a degree.