Steinberg v. Chicago Medical School
371 N.E.2d 634 · Illinois Supreme Court · 1977
Facts
Robert Steinberg applied to Chicago Medical School, paid a $15 fee, and was rejected. He filed a class action alleging the school breached a contract and committed fraud by failing to evaluate applications based on advertised academic criteria, instead using monetary contributions.
Issue
Can an applicant maintain claims for breach of contract and fraud against a medical school that allegedly failed to evaluate applications based on advertised academic criteria, and is this suitable for a class action under new statutory rules?
Holding
The court held that the breach of contract and fraud claims could proceed, reversing the dismissal of Count III (fraud) and expanding the scope of the class action to include all applicants who paid a fee based on the misrepresentations. It affirmed the dismissal of consumer fraud and unjust enrichment counts.
Rule
A contract can be formed when an applicant submits an application and fee in response to a school's advertised criteria, constituting an offer and acceptance with consideration. Fraud can be alleged when a false representation of future conduct (like evaluation criteria) is a scheme to accomplish fraud. Class actions are governed by statutory prerequisites including numerosity, common questions predominating, adequate representation, and appropriateness for adjudication.
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