The Fifth Circuit Court of Appeals affirmed a lower court's ruling dismissing a civil rights lawsuit filed by a former medical student against the University of Texas Southwestern Medical Center and several physicians. The decision, issued January 30, 2026, in *Gilani v. University of Texas Southwestern Medical Center*, rejected Al Gilani's claims that his dismissal from medical school violated federal civil rights laws.
Gilani sued UTSW and four doctors—Angela Mihalic, Blake Barker, WP Andrew Lee, and Dwain Thiele—under 42 U.S.C. § 1983 after the medical school dismissed him for what the institution characterized as unsatisfactory academic performance. The plaintiff argued his dismissal violated Title VI of the Civil Rights Act of 1964 and the Fourteenth Amendment's Due Process Clause.
The case originated in the U.S. District Court for the Northern District of Texas, where Gilani filed his complaint in 2021. The district court dismissed some of Gilani's claims and granted summary judgment to the defendants on others, prompting his appeal to the Fifth Circuit.
In a per curiam opinion, a three-judge panel consisting of Circuit Judges Richman, Engelhardt, and Wilson affirmed the district court's ruling. The appeals court specifically addressed Gilani's Title VI claims first, noting that the district court had granted summary judgment to UTSW on those claims and that Gilani had not successfully challenged that ruling on appeal.
Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, or national origin in programs receiving federal financial assistance. Medical schools like UTSW typically receive substantial federal funding through research grants and student financial aid programs, making them subject to Title VI requirements.
Section 1983 claims allow individuals to sue state actors for violations of constitutional rights. In this case, Gilani alleged that his dismissal violated his due process rights under the Fourteenth Amendment. Such claims in the academic context typically require plaintiffs to demonstrate that the institution's actions were arbitrary, capricious, or made in bad faith.
The Fifth Circuit's brief opinion indicates that Gilani failed to overcome the summary judgment standard on his various claims. Summary judgment is appropriate when there are no genuine disputes of material fact and the moving party is entitled to judgment as a matter of law.
Academic dismissal cases face significant hurdles in federal court. Courts generally defer to educational institutions' academic judgments, recognizing that faculty and administrators are better positioned to evaluate student performance than judges. The Supreme Court established in *Board of Curators of University of Missouri v. Horowitz* that academic dismissals require less procedural protection than disciplinary dismissals.
For Title VI claims specifically, plaintiffs must typically show intentional discrimination rather than merely disparate impact. This requires evidence that the institution acted with discriminatory intent, not simply that the challenged policy had a disproportionate effect on protected groups.
The case reflects broader challenges facing students who seek to challenge academic dismissals in federal court. Educational institutions enjoy substantial deference in academic matters, and courts are reluctant to second-guess professional educational judgments absent clear evidence of constitutional violations or discriminatory intent.
UT Southwestern Medical Center is part of the University of Texas system and one of the state's premier medical education institutions. The medical school maintains rigorous academic standards, and like other medical programs, regularly dismisses students who fail to meet performance requirements.
The Fifth Circuit's decision was designated as unpublished, meaning it will not be included in the official Federal Reporter and cannot be cited as precedent under Fifth Circuit rules. However, the ruling provides insight into how federal appeals courts handle academic dismissal challenges.
Gilani's unsuccessful appeal exhausts his options at the circuit level, though he could potentially seek Supreme Court review through a petition for certiorari. The high court rarely grants review in academic dismissal cases unless they present novel legal questions or conflicts between circuit courts.
The outcome reinforces the high bar plaintiffs face when challenging academic dismissals under federal civil rights laws. Educational institutions continue to enjoy broad discretion in academic matters, with courts intervening only in cases involving clear procedural violations or discriminatory conduct.
The case also highlights the intersection of medical education and civil rights law, an area where institutions must balance academic standards with anti-discrimination requirements. Medical schools face particular scrutiny given the importance of maintaining professional competency standards while ensuring equal educational opportunities.
For current medical students and educational institutions, the ruling underscores the importance of following established academic procedures and maintaining clear documentation of academic performance issues. While courts defer to academic judgments, institutions must still ensure their processes comply with constitutional due process requirements and federal anti-discrimination laws.