Garrett-Evangelical Theological Seminary: Student Discipline, Dismissal & Federal Court

How do student discipline and dismissal cases work at Garrett-Evangelical?

Garrett-Evangelical Theological Seminary is a private seminary of The United Methodist Church at 2121 Sheridan Road in Evanston, Cook County, on the Northwestern University campus. It is accredited by the Association of Theological Schools and the Higher Learning Commission, offers the MDiv, several MA degrees, the MTS, DMin and PhD, and reported 334 students to ATS in fall 2025. Garrett runs four separate “community standards” processes, and the one built specifically for ministry students is the most dangerous: a vocational standards review can end in discontinuance, and a student’s “unwillingness to engage in these procedures may lead to immediate discontinuance” without the remaining steps. Its Title IX policy, meanwhile, still contains an unfinished template where the standard of proof should be.

Garrett-Evangelical 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 Garrett-Evangelical 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 Garrett-Evangelical 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 Garrett-Evangelical 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.

Vocational standards: the review that decides readiness for ministry

The 2026–2027 Academic Catalog states that Garrett shares The United Methodist Church’s responsibility “for the selection and education of candidates” for ministry, so “the personal and professional qualities as well as the academic progress of each student are reviewed annually by the faculty,” and advancement in the professional degrees depends on the faculty’s affirmation of “growing readiness for ministry.” When a breach of vocational, professional or ethical standards is reported — “on or off campus (including personal and emotional)” — Academic Affairs reviews the report, notifies you, and holds a consultation with you and at least two academic affairs staff; an expanded consultation may follow. The criteria are personal ones: maintaining boundaries, self-regulation, dealing constructively with conflict, capacity to learn from experience, interpersonal relationships, working across difference, and empathy. Once a review starts you cannot switch degree programs, and if the consultations do not confirm your eligibility for ministry practice, “upon consultation with the Academic Dean the student may be discontinued.” The catalog adds that students “agree by their enrollment to accept these criteria and procedures.”

An appeal is available on four grounds only — new evidence, bias or discrimination, procedural error, or a disproportionate remedy — on the Student Standards and Accountability Appeal form, heard by the Academic Dean or a designee. No deadline, hearing or standard of proof is published for this process, and confirmed violations are “notated in the students’ academic record.” Because the review turns on contextual education and personal formation, it is where a field supervisor’s evaluation or a single conflict can become a dismissal case. See professionalism and fitness concerns.

Plagiarism and AI: the professor decides, and incidents add up

Garrett defines plagiarism to include material from “generative AI,” and any AI use “must be in consultation and agreement with the instructor(s),” with each syllabus setting the course rule. The procedure is short. The professor emails you the suspected violation “including all evidence,” such as a Turnitin report, meets with you, and then the professor alone determines whether a violation occurred; if so, the assignment receives an automatic F and Registration Services assigns an incident number. For master’s students, a second incident brings a conference with the Academic Dean and eligibility for discontinuance, and a third means “The student will be automatically discontinued from the degree program.” For doctoral students, discontinuance is possible after the first incident and automatic at the second. Every incident is recorded in the academic record. No hearing, standard of proof or appeal is published for a professor’s finding; the only general route is an academic petition, with “Appeals to the petition decision” directed to the Academic Dean. Contest a first finding immediately, in writing, because it counts toward the next — see AI-use accusations.

Academic standing and discontinuance

Standing is reviewed after fall and spring grades. Master’s students must keep a GPA above 2.5 and doctoral students 3.0; a first shortfall brings an academic warning and an invitation to an academic recovery program. The catalog’s discontinuance triggers are specific: an MDiv student “after accumulating three (3) grades of D or F,” two D or F grades in the same required course, “or an F in one semester of field education”; an MA student after two D or F grades or an F in field education; MTS and DMin students after two; PhD students after two grades below B-; and any degree student after two consecutive full-time semesters below the GPA minimum. No hearing or appeal is attached to academic discontinuance, and readmission requires a new application after two consecutive semesters showing the conditions “have been significantly addressed.” A student who skips two consecutive semesters without an approved leave is administratively withdrawn, and leave itself is capped at two consecutive semesters. Grade changes are limited to errors and, after posting, to “a suspected grading error or capricious grading.”

Conduct: preponderance, a silent support person, one appeal

Non-academic conduct runs through the Office of Student Affairs under the 2026–2027 Student Affairs Handbook, whose code “has been adapted from Northwestern University (NU)’s student code of conduct”; students in Garrett housing can also be referred to Northwestern. After an initial review you meet with at least two staff members; you may bring a support person, but the support person “is not permitted to speak or provide any evidence.” The Dean of Students may impose interim actions — no-contact orders, removal from housing, campus, a class or program — including “notification to relevant site supervisors, employers.” The standard is “the preponderance of evidence,” and remedies can include “mental health assessment and treatment.” Discontinuance is decided “in consultation with the Academic Dean.” You get one formal appeal to the Academic Dean, if you “can provide evidence that indicates remedies are not appropriate to the violation,” and that decision is final. No appeal deadline is published. See conduct code defense.

The Title IX policy that never chose its standard of proof

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). Garrett’s Sexual Misconduct Policy (revised December 2025) says it implements the 2020 regulation, and its procedures confirm the central feature of that rule: the 2020 regulation requires postsecondary institutions to hold a live hearing at which each party’s advisor conducts cross-examination. The policy provides a live hearing within 30 days of the final investigative report, an advisor of choice “who may be, but is not required to be, an attorney,” a seminary-provided advisor if you have none, at least 10 days to respond to the evidence and the report, and an appeal “Within 10 days of receiving the written determination” on three grounds; the policy does not say whether any of these day counts are calendar or business days. But where the standard of evidence belongs, the published text reads: “[SELECT OPTION: preponderance of the evidence standard/clear and convincing evidence standard.]” The template choice was never made. It also says it applies only to incidents “on or after August 1, 2024,” with earlier policies available from the Title IX Coordinator. If you are a party, ask in writing, before the hearing, which standard and which version will be applied — 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 Garrett-Evangelical’s catalog and handbook against what the seminary actually did and finding the gap; writing the response or the appeal so it argues the grounds the documents recognize 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.

Two moves fit Garrett’s rules. In a vocational standards review, engage fully and in writing — the catalog treats unwillingness to engage as a ground for immediate discontinuance — while building the four-ground appeal from the first consultation: bias, procedural error and disproportion are only arguable later if they were documented as they happened. In a Title IX case, the unfilled standard-of-proof clause is not a technicality; it is a written gap in the seminary’s own rule, and it belongs in a pre-hearing letter, not a post-decision complaint.

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 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 Garrett-Evangelical’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. Identify which of the four processes you are in — care and concern, vocational standards, Title IX, or student conduct — and ask in writing if it is unclear. The rights differ sharply between them.
2. Save the 2026–2027 Academic Catalog, the 2026–2027 Student Affairs Handbook and the December 2025 Sexual Misconduct Policy with dates visible, and any program, field education or contextual education handbook.
3. Calendar the only published appeal clock. A Title IX appeal is due within 10 days of the written determination. For conduct and vocational standards appeals, no deadline is published — file within days and ask for written confirmation it is timely.
4. Answer an integrity accusation at the meeting, in writing, with drafts, version history and any instructor permission for AI tools, before the professor decides.
5. Raise any disability now through Student Access; you can begin the process even without medical documentation. 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.

The federal money on the line at Garrett-Evangelical

Garrett-Evangelical Theological Seminary students took on $1.4 million in federal Direct Loans in the 2025–26 award year.

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, Garrett-Evangelical Theological Seminary’s most recent published composite score is 3.0 (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:

• Generations College
• Governors State University
• Hebrew Theological College
• Illinois College of Optometry
• Illinois Institute of Technology
• Institute for Clinical Social Work

Common questions about Garrett-Evangelical student cases

What is a vocational standards review at Garrett-Evangelical?

It is the catalog process for concerns about a student’s vocational, professional or ethical behavior, on or off campus, judged against criteria such as boundaries, self-regulation, handling conflict and empathy. It begins with a consultation with at least two academic affairs staff and can end in discontinuance after consultation with the Academic Dean. Refusing to engage can itself lead to immediate discontinuance. You may appeal to the Academic Dean on four grounds: new evidence, bias or discrimination, procedural error, or a disproportionate remedy.

How long do I have to appeal at Garrett-Evangelical?

It depends on the process. A Title IX determination may be appealed “Within 10 days of receiving the written determination,” in writing to the Title IX Coordinator; the policy does not say whether these are calendar or business days. The student conduct and vocational standards processes publish no deadline at all — each allows a single appeal to the Academic Dean. File as early as you can and ask for written confirmation that your appeal is timely.

Can Garrett-Evangelical dismiss me for plagiarism or AI use?

Yes. The professor decides whether a violation occurred after meeting with you, and the assignment gets an automatic F. A master’s student becomes eligible for discontinuance after a second recorded incident and is automatically discontinued after a third; a doctoral student is eligible after the first and automatically discontinued after the second. No hearing or appeal is published for the professor’s finding, so respond to the first accusation in writing.

What standard of proof does Garrett-Evangelical use?

Student conduct cases use preponderance of the evidence — “more likely true than not, and greater than 50% probable.” The Title IX policy is different: where the standard should be, the December 2025 text still reads “[SELECT OPTION: preponderance of the evidence standard/clear and convincing evidence standard.]” Vocational standards reviews and plagiarism findings publish no standard. Ask in writing which standard will apply before any decision.

Can I bring a lawyer to a Garrett-Evangelical hearing?

In a Title IX matter, yes: your advisor of choice may be an attorney, attends meetings, and conducts cross-examination at the live hearing, though advisors may not otherwise actively participate. In a student conduct review the rule is narrower — you may bring a support person, who “is not permitted to speak or provide any evidence.” The vocational standards process says nothing about advisors, so ask in writing before the consultation.