Warning
Info
- - tl;dr
- - ICRA
- - Facts & Holding
- - DeepDive
0 0
New York Court of Appeals - 87 N.Y.2d 384
tl;dr:
A student took the SAT but the administrator suspected him of cheating. When he submitted evidence as part of the resolution process set out in the registration bulletin. But the administrator just didn't take it into account.Video Summary
Case Summary
In the case of Dalton v. Educational Testing Service (1995), a student taking the SAT exam twice sued the test administrator for breach of contract when his second score was cancelled. The student argued that he provided enough proof to validate his second score, which was significantly higher than his first, but the test administrator relied only on handwriting analysis to doubt it. The test administrator claimed that they had the right to cancel scores if they doubted their validity based on the signed registration bulletin.
The trial court sided with the student, ordering the release of his second score, and the appellate court agreed. The Court of Appeals modified the decision, stating that under New York law, every contract has an implied obligation of good faith and fair dealing. They found that the test administrator breached this obligation by not adequately evaluating the student's evidence. The court ruled that the test administrator must comply with their own security procedures, which allows for the student to provide rebuttal evidence.
However, the court decided that the appropriate solution was not releasing the student's second score, but requiring the test administrator to genuinely consider his evidence. This case exemplifies how courts use state law and contract principles to interpret contracts and balance justice, fairness, autonomy, and discretion for involved parties. It also stresses the importance of clear communication in contract drafting to prevent disputes.
DeepDiveHighlight a legal term to see the definition
The court found that ETS breached its contract with a high school student by not acting in good faith when it refused to release his SAT score due to handwriting disparity and a significant difference between his May and November test results. Despite presenting additional evidence, ETS continued to question the validity of the student's November score and failed to evaluate the information submitted by the student. The court ordered specific performance as the appropriate remedy and upheld the trial court's decision that ETS breached its contract by disregarding the evidence provided by the student and failing to act in good faith and fairly in determining the legitimacy of the score.
The case involves Peter Dalton's suit against ETS, the administrator of scholastic aptitude tests. Dalton claimed that ETS treated his son unfairly by not conducting a thorough investigation of the material submitted when his scores were questioned. The lower court accepted Dalton's argument, citing ETS's failure to investigate, but the majority opinion correctly determined that ETS had no duty to investigate and that the lower court's finding of a breach of the implied covenant of good faith and fair dealing was based on an incorrect legal standard. ETS fulfilled its contractual obligations, and the complaint should be dismissed. The court found that there was no evidence of bad faith and that ETS did not act arbitrarily or irrationally in questioning the validity of Dalton's second test score based on the disparate handwriting. Therefore, ETS did not breach the implied covenant of good faith by refusing to certify Dalton's scores.
LSD+ Case Briefs
Features
- DeepDive for detailed case analysis
- Over 50,000 existing case briefs
- Instant briefs for another 6,000,000 cases
- Highlight dictionary for legal term definitions
- Social learning with chat and high points
Over 50,000 Cases Briefed
LSD+ gives you access to over 50,000 case briefs, more than anyone else. Be the first to email us the website of a case brief product that offers you more case briefs and we'll give you a free year of LSD+.
14-Day Free Trial
Unlimited access. Read as much content as you want during your trial with no device limitations. Cancel any time during your trial and keep access for the full 14 days.
Integrated Legal Dictionary
Lawyers and judges love to use big words. And Latin, for some reason.
Highlight a legal term in LSD Briefs and get an instant, plain English definition. Try highlighting contract or specific performance. No need to search or read through a list of definitions, simply highlight the words you don’t know and our LSDefine integration will instantly give you a definition to any of over 30,000 legal terms.
DeepDive
DeepDive allows you to explore legal cases like never before. DeepDive offers multiple levels of case summaries, which empowers you to quickly and easily find the information you need to stay on top of readings. Easily navigate through summary levels and click on any text to get more detail, all the way down to the original legal case text.
Brief anything. Instantly.
Our proprietary state-of-the-art system can instantly brief over 6,000,000 US cases. That means we can probably brief that case that your professor assigned last night when she sent you a poorly scanned pdf and told you to read every third paragraph. Or maybe she uploaded it to Canvas and didn’t really tell you to read it, but you know you probably should. Tenure does wild things to good people.
Social Learning with Chat and High Points
Study groups are a great way to learn and explore a case. LSD has chat rooms for each case to let you ask questions across the community and hear what other students struggled with and how they put it all together. Learn the key points of every case from other LSD+ users and share your knowledge with LSD High Points.
Real-Time Brief Feedback
Don’t settle for mistakes in briefs that have been there for 10 years and never fixed. Find an issue or something missing from a brief? Down vote and we will make improvements. All of our case brief editors graduated from from T14 law schools.