Yale University is off the hook for mistakenly confirming the credentials of an art history professor to a South Korean university.
The 2nd Circuit ruled on Thursday that the Ivy League institution was not guilty of negligence, defamation and reckless conduct in the case, since its administrators did not act with actual malice when confirming the degree.
Dongguk University filed suit in 2008, claiming that it was “publicly humiliated and deeply shamed in the eyes of the Korean population” after it came to light that one of its professors, Shin Jeong-ah, had lied about receiving her doctorate from Yale.
At the time of Shin’s 2005 hiring, she provided Dongguk with a document, printed on Yale letterhead, that apparently certified her degree in art history. Dongguk, in turn, forwarded the certificate to Yale, where an administrator confirmed its authenticity.
Several years later, however, Dongguk learned that Shin may have plagiarized parts of her dissertation and contacted Yale to report its suspicions. At that time, Yale told the South Korean university that Shin had never received a Ph.D. from the school. The revelation caused a scandal in South Korea, leading to the resignation of a former presidential aide who purportedly helped Shin obtain her teaching position, ostensibly because the two were having an affair.
Dongguk sued Yale, claiming that it lost more than $50 million in grants, donations and other damages, the Washington Post reports. But the 2nd Circuit found that Dongguk had failed to prove either that Yale administrators knowingly confirmed the false degree or that Yale’s mistake led to significant reputation harm.
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