GUPTA v. NEW BRITAIN GENERAL HOSPITAL12/31/1996
pecific contractual promise distinct from any overall obligation to offer a reasonable program. See, e.g., Cencor, Inc. v. Tolman, supra, 868 P.2d 399; Paladino v. Adelphi University, supra, 89 App. Div.2d 92.
In this case, the plaintiff has neither alleged nor presented factual evidence of a fundamental failure on the part of the hospital's residency program. Rather, his claims fall into two categories: (1) general allegations of inadequacy; and (2) more specific allegations that the hospital failed to attain "the standards established for teaching hospitals." With regard to the first category, the plaintiff has done no more "than simply allege that the education was not good enough." Ross v. Creighton University, supra, 957 F.2d 416-17. This, in turn, is insufficient to state a cause of action. See id.; Cencor v. Tolman, supra, 868 P.2d 398. With regard to the second category, the hospital's alleged failure to live up to the promise contained in the residency agreement that the hospital "is, and will continue to be, properly accredited by all necessary accrediting authorities," the plaintiff failed to adduce, in the trial court, any evidence either that the hospital had lost its accreditation or that its accreditation was in serious jeopardy.
We conclude, accordingly, that the trial court properly determined that the plaintiff's second claim was "without a factual basis" and, therefore, properly
granted summary judgment in favor of the hospital on this claim. See Doty v. Mucci, supra, 238 Conn. 805-806.
B
The plaintiff further contends that his dismissal was improper, even as an academic decision, because the decision to terminate his residency resulted from arbitrary, capricious, and bad faith conduct by the hospital. The trial court rejected this claim, finding that the plaintiff had failed to allege or to offer evidence in its support. We agree.
As with the plaintiff's claim of deficiencies in his hospital training, we approach with caution, and with deference to academic decisionmaking, the plaintiff's challenge to the motivation of the hospital in terminating his residency. "Like the decision of an individual professor as to the proper grade for a student in his course, the determination whether to dismiss a student for academic reasons requires an expert evaluation of cumulative information and is not readily adapted to the procedural tools of judicial or administrative decisionmaking." Board of Curators v. Horowitz, supra, 435 U.S. 90; see also Regents of the University of Michigan v. Ewing, 474 U.S. 214, 225-26, 106 S.Ct. 507, 88 L.Ed.2d 523 (1985); Doherty v. Southern College of Optometry, 862 F.2d 570, 576 (6th Cir. 1988), cert. denied, 493 U.S. 810, 110 S.Ct. 53, 107 L.Ed.2d 22 (1989); Lekutis v. University of Osteopathic Medicine & Health Services, 524 N.W.2d 410, 413 (Iowa 1994); Abbariao v. Hamline University School of Law, 258 N.W.2d 108, 112 (Minn. 1977); Olsson v. Board of Higher Education, 49 N.Y.2d 408, 416, 402 N.E.2d 1150, 426 N.Y.S.2d 248 (1980); cf. Mahavongsanan v. Hall, 529 F.2d 448, 450 (5th Cir. 1976) (for dismissal grounded in disciplinary, rather than academic, reasons, courts> appropriately may engage in more thorough due process analysis).
Judicial circumspection is particularly warranted in the context of academic decisions concerning medical competency. Put simply, "courts> are not supposed to be learned in medicine and are not qualified to pass opinion as to the attainments of a student in medicine." Connelly v. University of Vermont & State Agricultural College, 244 F. Sup. 156, 160-61 (D.Vt. 1965); see also Jansen v. Emory University, 440 F. Sup. 1060,
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