Simpson 1

Nikki Simpson
Case Review
EDLD 8431
Fall 2014
Waliga v. Board of Trustees of Kent State University
As stated in summation of Crook v. Baker (1987), the facts of Waliga v. Board of
Trustees of Kent State University (1986) are that Kent State University received
information regarding discrepancies in academic records and determined that two
students did not complete the requirements for their degrees and were notified that the
university was considering revoking the degrees. According to The Bryan Times (1983),
grades were changed for three Kent State University students, George Waliga, Kent
Taylor, and Stephen Hughes, in the 1960s. Hughes attempted to blackmail Waliga by
threatening to reveal the changing of seventy grades for the three men. With the
cooperation of Waliga, Hughes was arrested. During this incident the altered grade issue
was revealed and the Board of Trustees of Kent State University decided to hold a
hearing to discuss the matter and decide if the degrees should be revoked (The Bryan
Times, 1983).
The issue raised in Waliga v. Board of Trustees of Kent State University is
whether a university has the authority to revoke degrees that were improperly awarded.
The court found that a board of trustees does have the authority to revoke degrees when
there is proper cause and there is a fair hearing procedure.
The court noted that academic degrees are a statement that the recipient has met
the institutions standards and has fulfilled all requirements for graduation. If institutions
of higher education do not have a course of action to revoke a degree, the university is in
essence certifying that a person has fulfilled requirements when they have not. If this type

Simpson 2
of occurrence happened frequently it would lead to a breakdown in the integrity of
degrees. If a degree is awarded in error or it is found that the recipient received the degree
through an act of fraud that universities have an implied authority to revoke it based on
R.C. 3341.04, which states that universities shall do all things necessary for the proper
maintenance and successful and continuous operation of such universities. The opinion
in Waliga v. Board of Trustees of Kent State University (1986) stated, The power to
confer degrees necessarily implies the power to revoke degrees erroneously granted.
The court also noted an earlier ruling in The King v. University of Cambridge
(1334) in which it was decided that a man has a right to a hearing before being deprived
of property. Cleveland Board of Education v. Loudermill (1985) found that a degree
holder does have a right to his degree and without adequate procedures that right
cannot be withdrawn.
The case notes in Waliga v. Board of Trustees of Kent State University noted that
the appellees in the case were informed in writing of Kent State Universitys plan to
commence degree revocation procedures, were given time to review the evidence the
university would introduce at the hearing, were given notice of the hearing, and had
opportunity to present evidence and address witnesses.
The case notes made it clear that Kent State University had a procedure of due
process in place and it was adequately used in this case. The general rule from this case is
that universities do have authority to revoke academic degrees provided due process is
followed. The decision made in Waliga v. Board of Trustees of Kent State University
reversed the decision made at the court of appeals and all judges concurred with the
opinion.

Simpson 3
References
Cleveland Board of Education v. Loudermill, 470 U.S. 532 (1985).
Crook III v. Baker, 813 F. 2d 88 (1987).
Former attorney faces sentence. (1983, January 20). The Bryan Times, 11. Retrieved from
http://news.google.com/newspapers?nid=799&dat=19830120&id=DZhjAAAAIB
AJ&sjid=QVIDAAAAIBAJ&pg=6534,1951207
R.C. 3341.04
The King v. University of Cambridge (Bentley's Case) (K.B. 1723), 8 Modern Rep.
(Select Cases) 148, 92 E.R. 818, 2 Ld. Raym. (1334).
Waliga V. Board of Trustees of Kent State University, 22 Ohio St. 3d 55, 488 NE2d 850
(1986).