Brown et al v. Texas A&M University School of Law et al

Filing 1

COMPLAINT WITH JURY DEMAND against Andrew P. Morriss, Frederick G. Slabach, Texas A&M University School of Law, Texas Wesleyan University filed by R. Renee Jolley, Kathryn Freed-Collier, Jeff Fletcher, Maria Jackson Branch, Bryan Eggleston, Kristin R. Brown, Kathleen Hennessey Smith, Julie Glover, Terance Grisso, Cynthia Cooper Spigel, Kevin Ray Walden, Suzanne Stevens, Adam Miller, Deborah Johnson, Jared Julian, Amanda M. Coffey, Elliott Smith, Cherry L. Davis, Amy Theresa Ford, Patricia Donovan Henderson, Mark Lane, Norma A. Bazan, Monty J. Buhrow, Roxie Roll, Jennifer Browning Ledbetter, Payam Ghassemi Dell, Venisa McLaughlin, Myron Eugene Kimball, Jr, Riley C. Massey, Janice Eggleston, Adam Luck, Charles E. Ames. (Filing fee $400; Receipt number 0539-6987669) Clerk to issue summons(es). In each Notice of Electronic Filing, the judge assignment is indicated, and a link to the Judges Copy Requirements is provided. The court reminds the filer that any required copy of this and future documents must be delivered to the judge, in the manner prescribed, within three business days of filing. Unless exempted, attorneys who are not admitted to practice in the Northern District of Texas must seek admission promptly. Forms, instructions, and exemption information may be found at www.txnd.uscourts.gov, or by clicking here: Attorney Information - Bar Membership. If admission requirements are not satisfied within 21 days, the clerk will notify the presiding judge. (Attachments: # 1 Cover Sheet Cover Sheet, # 2 Exhibit(s) Appendix) (Norred, Warren)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
KRISTIN BROWN,
on behalf of herself and all others
similarly situated,
CHARLES AMES, NORMA BAZAN,
MARIA BRANCH, MONTY BUHROW,
AMANDA COFFEY, CHERRY DAVIS,
PAYAM DELL, BRYAN EGGLESTON,
JANICE EGGLESTON, JEFF
FLETCHER, AMY FORD, KATHRYN
FREED-COLLIER, JULIE GLOVER,
TERANCE GRISSO, PATRICIA
HENDERSON, DEBORAH JOHNSON,
RENEE JOLLEY, JARED JULIAN,
MYRON KIMBALL JR., MARK LANE,
JENNIFER LEDBETTER, ADAM LUCK,
RILEY MASSEY, VENISA
MCLAUGHLIN, ADAM MILLER, ROXIE
ROLL, ELLIOT SMITH, KATHLEEN
SMITH, CYNTHIA SPIGEL, SUZANNE
STEVENS, and KEVIN WALDEN,
Plaintiffs.

§
§
§
§
§
§ No. 4:15-CV-613
§ CLASS ACTION
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
§
v.
§
§
TEXAS A&M UNIVERSITY
§
SCHOOL OF LAW,
§
DEAN ANDREW P. MORRISS,
individually and in his official capacity, §
TEXAS WESLEYAN UNIVERSITY, and
§
PRESIDENT FREDERICK G.
§
§
SLABACH,
individually and in his official capacity, §
Defendants.
4:15-CV-613, Brown v. Texas A&M University School of Law
APPENDIX

Page 1

APPENDIX
TO PLAINTIFFS’ ORIGINAL COMPLAINT
Ex. A: Addendum to Prospectus ......................................................................... 1
Ex. B: Press Release ............................................................................................ 3
Ex. C: Webpage of 2012 Employment Statistics ................................................ 9
Ex. D: First Excerpt of The Aggie Lawyer ........................................................ 11
Ex. E: Second Excerpt of The Aggie Lawyer ..................................................... 12
Ex. F: LSAC Webpage ....................................................................................... 13
Ex. G: ABA Webpage ......................................................................................... 14
Ex. H: ABA Complaint ...................................................................................... 15
Ex. I: 2014 Standard 509 Report ...................................................................... 40
Ex. J: Joint Letter to SACS ............................................................................... 42
Ex. K: TAMU Letter to SACS ........................................................................... 43

4:15-CV-613, Brown v. Texas A&M University School of Law
APPENDIX

Page 2

Ex. A

OFFICE OF THE PROVOST

April 19, 2013

Cheryl D. Cardell
Vice President
Southern Association of Colleges and Schools
Commission on Colleges
1866 Southern Lane
Decatur, GA 30033
Dear Dr. Cardell:
Enclosed please find an addendum to our prospectus proposing the acquisition of Texas Wesleyan
University School of Law by Texas A&M University.
As you and I discussed, and at your invitation, we submit in our addendum a clarification of our
request for an exemption of Comprehensive Standard 3.6.3. Our best estimate is that
approximately 180 students may be affected by this standard in our substantive change request.
Thank you very much for your guidance and for the opportunity to provide clarification. Please
do not hesitate to let me know ifthere are further questions or additional materials Texas A&M
can provide.
Sincerely,

amela R. Matthews
Vice Provost for Academic Affairs

cc:

R. Bowen Loftin
Karan L. Watson
Frederick G. Siabach
Frederic White
Deena J. McConnell

RucleJer Tower gil, floor

12'18 TAMU
College Station, TX 778 '13-1248 USA
Tel. + 1 970.845.4016 Fax.
lHtp:llprovost.tal nu.edul

~

1 979.845.6994

Appendix p. 1

Ex. A
Addendum
to
Prospectus: Proposed Acquisition of
Texas Wesleyan University School of Law
by Texas A&M University

In our request for approval to acquire Texas Wesleyan University School of Law (TWUSL),
Section 4: Description of the Change, addresses changes in degree-granting authority. We would
like to clarify that in seeking approval at the June 2013 meeting of the SACSCOC Board of
Trustees, for the substantive change listed above, we also respectfully request an exemption from
Comprehensive Standard (C.S.) 3.6.3 for students who, at the time of the proposed
implementation date, are enrolled in the law program at Texas Wesleyan University School of
Law.
Although we anticipate relatively few instances where this requested exemption will apply, CS
3.6.3 requires that "At least one-third of credits toward a graduate or a post-baccalaureate
professional degree are earned through instruction offered by the institution awarding the
degree." An estimated 183 students who are currently enrolled at TWUSL may complete their
degree requirements having received less than one-third of their credits from Texas A&M
University. This would be a combination of full-time and part-time students who are nearing
completion.
It is the case that, if the acquisition is approved, there will be no cUlTicular changes, no changes
in the faculty who teach the current students, and no changes in the level of support services
provided to students who may seek to graduate with less than one-third of their program
requirements from Texas A&M.

April 19,2013

Appendix p. 2

Ex. B

News & Media Resources

Media / News & Media Resources / News Stories

LAW SCHOOL
AWARDED FOR
"SMART MOVES"
November 13, 2013
Texas A&M University School of Law was presented
the Fort Worth Business Press 2013 Smart Moves
Award at a formal reception, Wednesday night,
Nov. 13, at the newly‐opened Sundance Square
Pavilion in downtown Fort Worth.

Appendix p. 3

Ex. B

Nick S. Karanges, publisher of the Fort Worth Business Press, Mike Barber,
Fort Worth area president of Capital One
Bank, Aric Short, interim dean and professor of law at Texas A&M
University School of Law, and Dee J. Kelly Jr.,
managing partner of Kelly Hart & Hallman LLP ‐ photo courtesy of Kenneth

Perkins, The Fort Worth Business Press
Smart Moves, an event organized by the Fort

Worth Business Press, honored area businesses
who have made strides to improve or expand their
industry. The award recognizes 10 local businesses
for success, growth, and smart moves over the past
year. Sponsored by Capital One Bank and Kelly
Hart & Hallman LLP, the businesses are also
featured in a 20‐page special insert in the Nov. 18‐
24 issue of the Fort Worth Business Press.

Appendix p. 4

“We’re

Ex. B

delighted to be named to this year’s Fort Worth

Business Press Smart Moves list. In this historical
year as Texas A&M University School of Law, we
are honored to be recognized for our innovation
and progress. I am tremendously proud of our
academic program, which emphasizes critical
thinking, effective communication and
professionalism,” Aric Short, interim dean of Texas
A&M University School of Law, said.
“Our institution has seen great growth and
development in our short 24 year history, and
now, as part of a comprehensive Tier One research
institution with a decades‐long commitment to
excellence in the classroom and in the community,
we are excited to build upon the foundation of
our past successes.”
Texas A&M University School of Law is committed
to providing its students with the strong
theoretical foundation and practical lawyering
skills necessary to traverse the dynamic legal
landscape of the 21st century. The law school
pursues its mission of excellence through
outstanding teaching and scholarship, the
development of innovative academic and

Appendix p. 5

experiential learning programs, and a commitment

Ex. B

to public service and community outreach. To date,
Texas A&M law students have provided more than
120,000 hours of pro bono legal services which
equates to more than $2.4 million in total legal
services given to the community.
The law school prides itself on its ability to prepare
students for the demands of the legal profession
through rigorous coursework, specialized
certificate programs, externship opportunities, and
a multitude of practical training centers and clinics
designed to give the individual student the most
comprehensive training available. One example of
our educational approach is the Center for
Intellectual Property (CLIP), an integrated legal
educational center designed to give law students
an in‐depth understanding of intellectual property
law. CLIP’s core curriculum which combines
theoretical learning, clinical training and
community service, enables our students to
interact and learn from the best and the brightest
in the field.
“It is my pleasure to lead such a talented group of
faculty and staff as we move into a new era for
our law school, one of great growth and promise
as we anticipate collaborative educational
programs and developments with Texas A&M
University. In our short three months as Texas A&M
University School of Law, we have already planned
to debut an integrated J.D./engineering program
Appendix p. 6

in spring 2014. We greatly appreciate Fort Worth’s

Ex. B

support as we work to transform legal education,”
Short said.
Carolina Beverage, Leading Edge Aviation Services
and Sundance Square are among the other
awardees included in the 2013 list.  Texas A&M
School of Law was the only educational institution
honored.

Apply

Give

Academic Calendar

Library

Events

Bookstore

Contact Us

Texas A&M University School of Law
1515 Commerce Street
Fort Worth, Texas 76102‐6509
Local: 817.212.4000
Toll Free: 800.733.9529

Appendix p. 7

Emergency Information

Ex. B

Texas A&M University
Web Accessibility
Site Policies

ABA Required Disclosures
Privacy
Open Records

Stay Connected

© 2015 All Rights Reserved

Appendix p. 8

Ex. C

Careers and the Aggie Network

Prospective Students / Careers and the Aggie Network / Employment Statistics

EMPLOYMENT
STATISTICS FOR THE
CLASSES OF 2014,
2013, AND 2012

Contact
Career
Services
817‐212‐4050
817‐212‐4059 fax
Monday – Thursday,
9 a.m. to 6 p.m.

Nine months after graduation

Friday, 9 a.m. to 5
p.m.

Class of 2014

After‐hours
counseling
available by

Class of 2013

appointment.

Class of 2012

Apply

Give

Appendix p. 9

Academic Calendar

Ex. C

Library

Events

Bookstore

Contact Us

Texas A&M University School of Law
1515 Commerce Street
Fort Worth, Texas 76102‐6509
Local: 817.212.4000
Toll Free: 800.733.9529

Emergency Information
Texas A&M University
Web Accessibility
Site Policies

ABA Required Disclosures
Privacy
Open Records

Stay Connected

© 2015 All Rights Reserved

Appendix p. 10

Ex. D

Appendix p. 11

Ex. E

Appendix p. 12

Ex. F

Appendix p. 13

Ex. G

Appendix p. 14

Ex. H

Appendix p. 15

Ex. H

Appendix p. 16

Ex. H

Appendix p. 17

Ex. H

Appendix p. 18

Ex. H

Appendix p. 19

Ex. H

Appendix p. 20

Ex. H

Appendix p. 21

Ex. H

Appendix p. 22

Ex. H

Appendix p. 23

Ex. H

Appendix p. 24

Ex. H

Appendix p. 25

Ex. H

Appendix p. 26

Ex. H

Appendix p. 27

Ex. H

Appendix p. 28

Ex. H

Appendix p. 29

Ex. H

Appendix p. 30

Ex. H

Appendix p. 31

Ex. H

Appendix p. 32

Ex. H

Appendix p. 33

Ex. H

Appendix p. 34

Ex. H

Appendix p. 35

Ex. H

Appendix p. 36

Ex. H

Appendix p. 37

Ex. H

Appendix p. 38

Ex. H

Appendix p. 39

Texas A&M University - 2014 Standard 509 Information Report

12312312 Ex. I

12312312

1515 Commerce Street

ABA

Fort Worth, TX 76102
Texas A&M University
Phone: [phone]

Approved

Website: http://law.tamu.edu/

1994

Since

The Basics

GPA and LSAT Scores (calendar year**)

Type of school

PUBLIC

Term

Semester

Application deadline

3/31/2015

Application fee

$ 55

Total

1,714

290

797

719

78

# of matriculants

192

155

37

75th Percentile GPA

3.41

3.41

3.34

50th Percentile GPA

3.21

3.22

3.18

25th Percentile GPA

Tuition and Fees (academic year*)

2,004

# of offers

No

Can first year start other than fall?

Part-Time

# of apps

Financial aid deadline

Full-Time

2.93

2.92

2.95

3

2

1

Resident

Non-Resident

Full-Time

$ 33,092

$ 33,092

75th Percentile LSAT

156

156

155

Part-Time

$ 24,068

$ 24,068

50th Percentile LSAT

154

154

153

25 Percentile LSAT

152

152

151

0

0

0

Tuition Guarantee Program

# not incl. in GPA percentile calc.

No

Living Expenses (academic year*)

# not incl. in LSAT percentile calc.

Estimated Living Expenses for singles

Grants and Scholarships (prior academic year*)

Living on Campus

Total

$ 21,828

Living at Home

#

%

771

100

469

60.8

302

39.2

697

90.4

440

93.8

257

85.1

656

85.1

405

86.4

251

83.1

37

4.8

32

6.8

5

1.7

Full tuition

4

0.5

3

0.6

1

0.3

More than full tuition

Conditional Scholarships

%

Total # receiving grants

$ 21,828

#

Total # of students

$ 21,828

0

0

0

0

0

0

Half to full tuition

# Entering with

2013-2014 Academic Year

Part-Time

%

Less than 1/2 tuition

Living Off Campus

Students Matriculating in

Full-Time

#

# Eliminated

89

48

75th Percentile grant amount
2012-2013 Academic Year
2011-2012 Academic Year

137
126

$ 1,288

$ 1,397

25th Percentile grant amount

81

$ 1,397

50th Percentile grant amount

84

$ 7,538
$ 1,288

$ 1,397

J.D. Enrollment and Ethnicity (academic year*)
Men

Part-Time

%

#

%

#

%

#

%

#

%

#

%

#

%

Hispanics of any race

52

14.4

48

14.1

0

0

65

14.2

35

14.3

58

15.8

100

14.2

30

American Indian or Alaska
Native

2

0.6

2

0.6

0

0

3

0.7

1

0.4

2

0.5

4

0.6

1

Asian

10

2.8

11

3.2

0

0

12

2.6

9

3.7

10

2.7

21

3

9

Black or African American

15

4.1

36

10.6

0

0

30

6.6

21

8.6

26

7.1

51

7.3

11

Native Hawaiian or Other Pacific
Islander

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Two or more races

10

2.8

8

2.4

0

0

9

2

9

3.7

8

2.2

18

2.6

6

Total Minority

89

24.6

105

30.9

0

0

119

26

75

30.7

104

28.3

194

27.6

57

White

262

72.4

227

66.8

0

0

327

71.4

162

66.4

254

69

489

69.7

170

Nonresident Alien

1

0.3

2

0.6

0

0

3

0.7

0

0

3

0.8

3

0.4

1

Race and Ethnicity Unknown

10

2.8

6

1.8

0

0

9

2

7

2.9

7

1.9

16

2.3

4

Total

362

51.6

340

48.4

0

0

458

65.2

244

34.8

368

52.4

702

100

232

1

Texas A&M University

Women

Other

First - Year

J.D. Deg Awd

Full-Time

#

Total

Version:2014.4
Appendix p. 40

Ex. I
Texas A&M University
ABA
Approved
Since
1994

Curriculum (prior academic year*)

Faculty and Administrators (calendar year**)
Full-Time Part-Time

Typical first-year section size

73

# of classroom course titles beyond
first-year curriculum

Total

76

Men

Women

Other

Minorities

Spr Fall Spr Fall Spr Fall Spr Fall Spr Fall

105

Full-Time

28

26

16

17

12

9

0

0

6

6

13

12

4

3

9

9

0

0

1

1

100

Deans, librarians
& others who
teach
Part-Time

22

26

12

18

10

8

0

0

0

0

Total

63

64

32

38

31

26

0

0

7

7

# of upper division classroom course sections
Under 25
25 - 49

35

50 - 74

17

75 - 99

12

100+

Bar Passage Rates (February and July 2013)

1

First Time Takers: 185

# of positions available in simulation courses

480

# of simulation positions filled

266

109

# of seminar positions filled

116

57

# of positions available in faculty supervised law
clinic courses

137

# of faculty supervised law clinic positions filled

87

42

107

19

9

3

168

33

# of students who participated in
interschool skills competitions

47

13

# of credit hours required to graduate

90

# of field placement positions filled
# of students who enrolled in independent study
# of students who participated in law journals

Jurisdiction
Texas

Takers

Passers

Pass %

State %

180

156

86.67

85.08

Diff. %
1.59

Reporting
%

Avg. School
Pass %

Avg. State
Pass %

Avg. Pass
Diff. %

97.30

86.67

85.08

1.59

Bar Passage Rates (February and July 2012)
First Time Takers: 223
Jurisdiction
Texas

Takers

Passers

Pass %

196

167

State %

85.20

Diff. %

82.06

3.14

Reporting
%

Avg. State
Pass %

Avg. Pass
Diff. %

87.89

J.D. Attrition (prior academic year*)

Avg. School
Pass %
85.20

82.06

3.14

Bar Passage Rates (February and July 2011)

Academic

Transfer

Other

Total

#

#

#

#

%

1st year

19

4

11

34

7.6

2nd year

0

0

1

1

0.5

3rd year

1

0

0

1

1.6

Reporting
%

Avg. School
Pass %

Avg. State
Pass %

Avg. Pass
Diff. %

4th year

0

0

0

0

0

96.85

87.44

86.24

1.20

First Time Takers: 222
Jurisdiction
Texas

Takers

Passers

Pass %

State %

Diff. %

215

188

87.44

86.24

1.20

Transfers In (prior academic year*)
Total #

0

See Appendix for list of schools from which students transferred (only
applicable for schools with more than 5 transfers.)

* "Academic year" refers to the 2014 - 2015 academic year. ** "Calendar year" refers to the 2014 calendar year.

Version:2014.4

Appendix p. 41
2

Ex. J

Appendix p. 42

Ex. K

Appendix p. 43