Lake Forest College: Student Discipline, Dismissal & Federal Court

How do student discipline and dismissal cases work at Lake Forest College?

Lake Forest College is a private liberal arts college of about 1,800 undergraduates in Lake Forest, Lake County, thirty miles north of downtown Chicago, accredited by the Higher Learning Commission. It runs three separate tracks — a Code of Student Conduct administered by the Office of Campus Life, a faculty-run Academic Honesty Judicial Board, and an Academic Appeals Board for suspension and dismissal — and one rule shapes the first two: in a conduct or academic honesty case, your advisor must come from inside the College community and may not speak for you. An outside lawyer or a parent cannot fill that seat. The rule changes only when the allegation is sexual misconduct.

Lake Forest College 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 Lake Forest College is filed in the United States District Court for the Northern District of Illinois — Lake 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 Lake Forest College 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.

Conduct cases: five business days, and an advisor from inside

The Code of Student Conduct sits in the Student Handbook and is run by the Vice President for Campus Life and designated College Officials. An Administrative Hearing is a meeting with one official who decides responsibility and sanctions. A Conduct Board Hearing may be used, at the official’s discretion, where the possible sanction is suspension of more than ten instructional days, expulsion or revocation of a degree: a chair plus one faculty member, one staff member and one student, deciding by majority — “a unanimous vote is not required.” Either hearing is scheduled “no less than two (2) nor more than five (5) business days” after the Notice of Alleged Violation, and your witnesses must be named to the chair at least two school days ahead. The standard is preponderance of the evidence, technical rules of evidence do not apply, and the board only suggests sanctions; the Vice President’s designee decides them.

The appeal is due “within five (5) business days of receipt of an outcome letter,” on at least one of four grounds: material new information, a material procedural error, pre-existing bias, or a sanction not appropriate to the violation. Review is confined to the record, and appellate decisions are final. One sentence cuts the other way: “No student who appeals a sanction of expulsion shall be expelled from the College without the specific consent of the President of the College.”

The advisor rule. The one advisor allowed “may not speak, write or otherwise communicate with an investigator or with the College Official or Hearing Board on behalf of the student,” and “must be a member of the College Community (e.g. a student, faculty or staff member, etc.).”

Interim action. Where the evidence indicates a severe violation may have occurred, the Vice President for Campus Life can impose an interim suspension or campus ban effective on notification. The appeal is due to the Vice President “within 5 business of notification” — the handbook omits the word “days,” so read it as five business days — and a three-person panel normally responds within five business days.

Academic honesty: a jury of three and an appeal on procedure only

The handbook says it does not cover academic conduct; the Catalog’s Academic Honesty policy does. A faculty member who suspects cheating must tell you in writing, with a recommended sanction, and allow you “up to five business days” to respond. If you deny it or reject the sanction, the Academic Honesty Judicial Board hears the case, normally within one week: a non-voting faculty chair and a jury of one faculty member and two students, two of whose three votes decide. Your advisor must be “drawn from within the campus community,” and the policy publishes no standard of proof. A first offense carries an “expected minimum sanction” of zero points on the work; second and third offenses bring votes on recommending suspension or dismissal, which the President decides. The appeal is narrow — “A student may ask the Dean of the Faculty to consider an appeal on procedural grounds only” — and has no published deadline. The policy never mentions AI, so an AI-use accusation must be fitted into general language, and its core plagiarism definition speaks of work done by “another person.”

Academic standing: below 1.0 is suspension, the second suspension is permanent

A cumulative GPA below 2.0 brings probation. Once a student has completed a second semester, any term below 1.0 brings academic suspension even without prior probation, as does a probationary term below 2.0, and no one stays on probation more than two consecutive semesters. A suspended student cannot apply for readmission for at least six months and may be readmitted only once: “a second suspension for academic reasons is known officially as an Academic Dismissal,” permanent and on the transcript.

Every suspended student has “the right to appeal,” but the Catalog publishes no deadline. Appeals go to the Academic Appeals Board, and each “must also have attached a detailed statement from the advisor regarding the appeal,” so your academic advisor must be involved before you file; an exception to a faculty rule needs “a unanimous vote of all three voting members.” Grade disputes start with the department chair “within two calendar weeks following the beginning of classes in the term following the alleged injustice,” and the review committee changes a grade only unanimously. Lake Forest runs no clinical program of its own; its Nursing Pathways Program prepares students for a nursing master’s elsewhere, including at Rosalind Franklin University.

Sexual misconduct: even “current” is a question

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). At Lake Forest the documents disagree about which policy applies. The Student Handbook sends sex discrimination to “the College’s 2024-2025 Equal Opportunity, Harassment, and Nondiscrimination Policy.” That policy says the College implemented it “to align with the 2024 Title IX regulations,” then provides that “for sex- or gender-based harassment meeting Title IX requirements, the prior Title IX policy in effect before August 1, 2024 will govern.” The Title IX policy page labels as “Current” the College’s Interim Sex Discrimination and Sexual Misconduct Policy and Interim Title IX Sexual Harassment Complaint Resolution Procedures, written for the 2020 regulation, while listing a 2023–2024 policy as archived.

The document labeled current provides the live hearing the 2020 regulation requires — postsecondary institutions must hold a live hearing at which each party’s advisor conducts cross-examination — with one advisor per party “who may be an attorney,” and a preponderance standard. Hearing notice comes at least five calendar days ahead. The appeal is due “within five (5) calendar days of the date of receipt of the investigator’s Final Investigation Report or the written notice of sanctions, whichever is later,” and the document names its recipient two ways, as the chair of a “Sexual Misconduct Appellate Board” and of a “Title IX Sexual Harassment Appellate Board.” The EOHN policy allows five business days. Ask the Title IX Coordinator in writing, early, which document governs; more on these cases is on my Title IX page.

What a student defense lawyer can do here

Most of the value is early and quiet. It is reading Lake Forest’s policy against what the College 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 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 Lake Forest. Because the advisor in a conduct case must come from the College community and stay silent, a lawyer’s work there is behind the scenes: preparing you and your witnesses, writing the submissions, and helping you choose a faculty or staff advisor who will steady you. And in an expulsion case the appeal is written for two readers, since an appealing student cannot be expelled without the President’s “specific consent” — ask in writing what the President will be shown.

What a lawyer cannot do is turn a campus hearing into a trial. The rules of evidence do not apply, there is no discovery, and the College 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 Lake Forest College’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.

Outside the sexual misconduct process the handbook’s own rule governs: in a conduct or academic honesty case, the advisor comes from the College community and stays silent.

What to do first

1. Find the deadline and write it down. Five business days for a conduct appeal; a hearing as soon as two business days after the notice; calendar days under the Title IX procedure. Where Lake Forest publishes nothing — the suspension appeal, the academic honesty appeal — ask in writing for the date.
2. Choose your advisor now: a student, faculty member or staff member you trust, or an attorney in a sexual misconduct case.
3. Save the policy that governs your case, dated, including whichever Title IX document the Coordinator confirms in writing. The College says changes take effect once posted.
4. Ask, in writing, for the evidence — reports, statements and the verbatim recording the handbook says is kept of any Conduct Board hearing.
5. If grades are the problem, see your academic advisor first; the Board requires the advisor’s statement, and a disability or unmet accommodation that explains the semester belongs in the appeal now. For how Illinois cases work generally, 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 Lake Forest College

Lake Forest College students and families took on $7.8 million in federal Direct Loans in the 2025–26 award year — including $2.5 million borrowed by 112 parents through Parent 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.

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:

• Lewis University
• Lincoln College of Technology, Melrose Park
• Loyola University Chicago
• Lutheran School of Theology at Chicago
• McCormick Theological Seminary
• Meadville Lombard Theological School

Common questions about Lake Forest College student cases

Can I bring a lawyer to a Lake Forest College conduct hearing?

Not as your advisor in an ordinary conduct case. The Student Handbook allows one advisor, who “must be a member of the College Community” and may not speak, write or communicate with the hearing officer or board for you; academic honesty cases likewise require an advisor from within the campus community. A lawyer can still prepare you and your written submissions. In a sexual misconduct case, the advisor may be an attorney.

How long do I have to appeal a conduct decision at Lake Forest College?

Five business days from receipt of the outcome letter, in a letter stating at least one ground: material new information, a material procedural error, pre-existing bias, or a sanction not appropriate to the violation. Review is limited to the hearing record and the decision is final — but an appealing student cannot be expelled without the President’s specific consent.

What standard of proof does Lake Forest College use?

Preponderance of the evidence — more likely than not — in conduct cases and in sexual misconduct cases. The Academic Honesty policy publishes no standard at all; it says only that a finding of responsibility needs two of the three voting jurors, one faculty member and two students, which is worth raising if the case against you is thin.

I was academically suspended from Lake Forest College. Can I appeal, and by when?

Yes, to the Academic Appeals Board, but the Catalog publishes no deadline, so ask in writing for the date and file quickly. Attach the detailed statement from your academic advisor that the Catalog requires. If the appeal fails, you cannot apply for readmission for at least six months, and a second academic suspension becomes a permanent Academic Dismissal.

Can Lake Forest College suspend me before my hearing?

Yes. Where the evidence indicates a severe violation may have occurred, the Vice President for Campus Life can impose an interim suspension or campus ban effective on notification. Appeal in writing to the Vice President within five business days — the handbook’s text omits the word “days” — and a panel of three administrators normally responds within five business days.