Worsham College of Mortuary Science: Student Discipline, Dismissal & Federal Court

How do student discipline and dismissal cases work at Worsham College?

Worsham College of Mortuary Science is a private, for-profit mortuary college in Wheeling, in northern Cook County, founded in 1911, with 236 students by its own count. The American Board of Funeral Service Education (ABFSE) accredits both the college and its Associate of Science in Funeral Service, offered on campus and online. Its conduct appeal has a trap: the clock runs from the alleged infraction, not from the decision — evidence goes to the Program Director “within 7 days of the alleged infraction,” and the final written appeal to the Board of Directors is due “within 30 days of alleged infraction,” with neither labeled calendar or business days.

Worsham College of Mortuary Science 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 Worsham College of Mortuary Science 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 Worsham 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.

The conduct appeal: seven days, thirty days, a notary and a sealed envelope

The Code of Conduct allows discipline up to suspension or dismissal. After talking with the instructor or staff member, a student who disputes the accusation presents the evidence to the Program Director, in person or by phone, “within 7 days of the alleged infraction.” The last step is a written appeal to the Board of Directors “within 30 days of alleged infraction, and only after discussions have taken place with the Program Director,” with “written statements of witnesses’ sworn to before a notary public,” handed “to the Program Director in a sealed envelope to be forwarded to the Board of Directors.” The Board reviews it within 30 days, and “the decision reached by the Board of Directors is final.” No unit of days, standard of proof, hearing or advisor rule is published for conduct cases. See conduct code defense.

AI and plagiarism: a zero, then dismissal

The Code of Conduct treats as plagiarism “using AI tools, such as ChatGPT, to write assignments or respond to discussion prompts” unless the instructor allows it, and lets instructors use AI-detection software and writing comparisons. On a first offense “the student will receive a ‘0’ grade for the assignment” and the Program Director is notified; on a second, “the student will be dismissed from the program.” The Student Rights procedure leaves integrity and conduct cases to their own process, the conduct appeal above. See AI academic integrity accusations.

Academic progress: two probations, then a choice

Students need a 2.0 cumulative GPA and “a grade of ‘C’ (72) or better in all core courses.” A student who misses the progress standards can be on probation for “a maximum of two consecutive probationary periods”; after that the options are to “Repeat the program beginning with the first semester in one year,” or dismissal. “A student may repeat the same course a maximum of two (2) times,” and “If a student is unsuccessful after the second attempt, they will not be permitted to re-enroll in the program.” Two consecutive weeks of absence or Canvas inactivity means immediate withdrawal.

Appeals run two ways on the same page. SAP appeals go to the Program Director, “A student is allowed only one appeal,” and “Completed SAP appeals will be reviewed within 15 business days”; a denial goes in writing to the Academic Dean for the Board, which reviews it “within seven calendar days of receipt.” The probation section instead sends the appeal straight to the Board of Directors, which reviews it “within a week.” Use both addresses. See SAP appeals.

Grades and complaints: business days

The Student Rights page (updated September 2026) covers appeals of academic decisions, including grades. They “must ordinarily be submitted in writing within 7 business days” of notice, and “Disagreement with an instructor’s academic or professional judgment is not, by itself, grounds for appeal.” A final appeal “must be submitted in writing within 7 business days of the original decision” — read literally, a clock that can run out before the first appeal is decided, so ask in writing which decision starts it. General complaints “should ordinarily be filed within 15 calendar days.” See grade appeals.

Harassment and sexual misconduct

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). Harassment must be reported immediately, “not to exceed thirty days” (no unit stated). Worsham’s 2024 Annual Security Report adds the sexual misconduct procedure: “The College uses the preponderance of the evidence standard”; “A panel hearing will be used where the alleged violation has the potential to result in separation”; an advisor “may be any person of the party’s choosing, including an attorney,” but is “limited to the supportive and not participatory role”; and both parties may appeal, though no appeal deadline is published. See Title IX and sexual misconduct.

What a student defense lawyer can do here

Most of the value is early and quiet: reading Worsham’s policy against what the school actually did; writing the response or appeal on the grounds the policy recognizes, not 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 finding comparators, because a sanction far outside what similar cases drew is one of the few arguments that reliably moves a decision-maker.

At Worsham, the specific moves follow the clock: getting the evidence to the Program Director in writing within 7 days of the incident — even before a decision arrives — and gathering notarized witness statements early, because the Board appeal requires them. In an AI case, ask what detection report and what instructor permission exist.

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 Worsham 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 Worsham 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.

The conduct appeal, by contrast, names no advisor at all, so ask the Program Director in writing who may attend any meeting.

What to do first

1. Count from the incident, not the decision: 7 days to the Program Director, 30 days to the Board. No unit is stated, so count calendar days.
2. Get witness statements notarized now.
3. Save the handbook pages — Code of Conduct and Academic & Program Policies (October 2025), Student Rights (September 2026) — with the date visible.
4. Ask in writing for the evidence: proctor reports, AI-detection output and any files relied on.
5. If you must miss class, request a leave of absence in writing first; two weeks away means withdrawal. For how cases work across the state, 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 Worsham College

Worsham College of Mortuary Science students and families took on $1.2 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, Worsham College of Mortuary Science’s most recent published composite score is 0.2 (fiscal year 2022–23) — below the 1.0 line on the –1.0-to-3.0 scale, which means the school participates in the federal aid programs only under conditions the Department sets, such as extra monitoring or financial protection (34 C.F.R. §§ 668.171, 668.175). The scores run about two years behind and are one signal, not a verdict. How to read them: 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:

• Adler University
• American Islamic College
• Aurora University
• Benedictine University
• Bexley Hall Seabury Western Theological Seminary Federation
• CAAN Academy of Nursing

Common questions about Worsham College student cases

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

Count from the incident. Your evidence goes to the Program Director “within 7 days of the alleged infraction,” then a final written appeal, with notarized witness statements, to the Board of Directors within 30 days of the infraction. No unit is stated, so count calendar days. The Board’s decision is final.

What happens if I’m accused of using ChatGPT at Worsham College?

Unless your instructor allowed it, using AI tools such as ChatGPT to write assignments or discussion posts counts as plagiarism. A first offense means a zero on the assignment and notice to the Program Director; a second means dismissal from the program. Instructors may use AI-detection software, so ask for the report and answer in writing.

How many times can I repeat a course at Worsham College?

Twice. “A student may repeat the same course a maximum of two (2) times,” and a student unsuccessful after the second attempt may not re-enroll in the program. A full semester may be repeated “one time only,” and after two consecutive probations the options are restarting the program in a year or dismissal.

Can I bring a lawyer to a Worsham College hearing?

In a sexual misconduct case, an advisor may be an attorney, but only in a supportive, non-participatory role, according to the 2024 Annual Security Report. The conduct appeal is a written process ending with the Board of Directors, and the handbook names no advisor. Ask the Program Director in writing who may attend any meeting.