“Solely-By-Reason” and “Otherwise-Qualified” in Academic Programs – The Legacy of Royan v. Chicago State University

1. Introduction

On 22 July 2025 the United States Court of Appeals for the Seventh Circuit handed down its decision in Ayla Royan v. Chicago State University, No. 24-1734. The case concerned the dismissal of a doctoral pharmacy student who alleged disability discrimination under § 504 of the Rehabilitation Act of 1973. Judge Hamilton, writing for a unanimous panel (Hamilton, Kirsch, Maldonado JJ), affirmed summary judgment for the university and, in doing so, gave the most detailed post-Swain/Conners analysis of the Rehabilitation Act’s dual requirements in academic settings: (1) that a plaintiff be “otherwise qualified,” and (2) that disability be the sole cause of the adverse action.

The judgment synthesises and clarifies earlier Seventh Circuit precedents while adding two refinements that are likely to echo well beyond pharmacy schools:

1. An educational institution does not violate § 504 where undisputed academic failures render the student not “otherwise qualified,” even if the student excels in other coursework.
2. Where the ultimate evaluator lacks actual or constructive knowledge of a student’s disability, the “solely by reason of” standard cannot be met absent proof of a “cat’s-paw” chain of animus.

2. Summary of the Judgment

The Court affirmed the district court’s summary judgment because:

• Royan failed two required clinical rotations; therefore, under CSU policy she was ineligible to continue and was not “otherwise qualified.”
• No reasonable jury could find that CSU dismissed her “solely by reason of” her disabilities. Key to that holding was uncontroverted evidence that the second preceptor, Dr Kerner, had no knowledge of her disabilities, breaking any causal chain.
• Royan’s “pretext” argument failed: the record showed repeated accommodations rather than hostility, and inconsistencies in academic evaluations did not suggest dishonesty.

3. Detailed Analysis

3.1 Precedents Cited

• Khan v. Midwestern University, 879 F.3d 838 (7th Cir. 2018) – provided the basic template for evaluating “otherwise qualified” in professional-school contexts. The panel relied on Khan to hold that failing key program requirements places a student outside § 504’s protection.
• Novak v. Board of Trustees of SIU, 777 F.3d 966 (7th Cir. 2015) – underscored deference to academic judgments and rejected speculation about pretext absent concrete evidence. Royan uses Novak to emphasise that criticisms of evaluation methodology do not establish discrimination.
• Hedberg v. Indiana Bell Tel., 47 F.3d 928 (7th Cir. 1995) – an ADA case holding that an employer who has no knowledge of a disability cannot discriminate on that basis. The Seventh Circuit imports that principle into the § 504 academic setting, bolstering the knowledge requirement for causation.
• Swain v. Wormuth, 41 F.4th 892 (7th Cir. 2022) & Conners v. Wilkie, 984 F.3d 1255 (7th Cir. 2021) – recent cases clarifying that § 504 demands “sole cause” rather than the ADA’s “motivating factor.” Royan applies these rulings to the student-dismissal context.

3.2 Court’s Legal Reasoning

1. “Otherwise Qualified” Analysis
   • The court compared CSU’s program rules with Royan’s academic record.
   • Failing two clinical rotations is per se disqualifying because rotations are “core competencies.”
   • Prior good grades elsewhere do not resurrect qualification once an indispensable component is failed.
   • The panel echoed Regents v. Ewing in deferring to faculty on academic standards.
2. Pretext Inquiry
   • Pretext means dishonesty, not mistaken judgment.
   • Royan acknowledged several deficiencies and admitted voluntarily abandoning the first rotation.
   • Absence of record evidence that faculty lied or harboured hostility doomed the claim.
3. Sole-Cause Causation
   • Because Dr Kerner (decision-maker #2) was unaware of Royan’s disability, the chain of causation broke.
   • The “cat’s-paw” theory failed: Royan could not show that Dr Patel’s alleged animus was conveyed to or influenced Kerner.
   • The court effectively elevates knowledge to a gate-keeping element: no knowledge, no sole-cause discrimination.

3.3 Impact of the Judgment

Royan is poised to influence disability litigation in at least three dimensions:

1. Reinforced Deference to Academic Evaluations – By reiterating that courts cannot second-guess honest professional judgments, the decision provides universities a clearer litigation roadmap.
2. Knowledge Requirement Clarified – Plaintiffs must now plead and prove that the ultimate evaluator knew of the disability; mere institutional knowledge is insufficient.
3. Cat’s-Paw Boundaries in § 504 – The opinion limits cat’s-paw theories where record evidence of communication and influence is thin. Expect defendants to challenge speculative chains more aggressively.

4. Complex Concepts Simplified

• “Otherwise Qualified” – A person who can meet all legitimate program requirements with reasonable accommodation. If a requirement is essential (e.g., passing clinical rotations) and the student fails it, the student is no longer protected.
• “Solely by Reason of” – Under § 504, disability must be the single cause of the adverse action. Any other legitimate, non-discriminatory factor (such as academic failure) defeats liability.
• Pretext – A purported reason that is a lie hiding the true discriminatory motive. Courts look for inconsistencies, shifting explanations, or evidence that decision-makers didn’t actually believe what they stated.
• Cat’s-Paw Theory – A supervisor with bias (the “cat”) manipulates an unbiased decision-maker (the “paw”) to take action against the employee/student. Proof requires showing a causal chain of influence, not mere speculation.

5. Conclusion

Royan v. Chicago State University sharpens the boundaries of disability discrimination claims in higher-education programs. The Seventh Circuit made two decisive pronouncements: (1) students who fail essential academic components are not “otherwise qualified,” and (2) without credible evidence that disability was the sole cause—and that the evaluator knew of the disability—a Rehabilitation Act claim cannot survive. Future plaintiffs must therefore marshal concrete proof of both qualification and causation; universities, conversely, should document accommodations and preserve the insulation of evaluators from disability-related data where appropriate. The case stands as the authoritative blueprint for litigating (or defending) § 504 claims in the academic arena across the Seventh Circuit and is likely to be persuasive nationwide.