Cleland v. National Coll. Of Business, 435 U.S. 213 (1978)

ON APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF SOUTH DAKOTA

Syllabus

Provisions of the GI Bill requiring the Administrator of the Veterans’ Administration to disapprove the application of a veteran seeking educational assistance benefits if the veteran enrolls in a course in which more than 85% of the students are receiving financial assistance from the educational institution, the VA, or other federal agency (85-15 requirement), or if the course has been offered for less than two years, held not to violate the Due Process Clause of the Fifth Amendment. Experience with administration of the veterans’ educational assistance program since World War II having revealed to Congress a need for legislation that would minimize the risk that veterans’ benefits would be wasted on educational programs of little value, it was rational for Congress to conclude that established courses with a substantial enrollment of nonsubsidized students were more likely to be quality courses, and thus the 85-15 and two-year requirements both satisfy the constitutional test normally applied in cases like this. Such requirements are not made irrational by virtue of their absence from other federal educational assistance programs.

433 F.Supp. 605, reversed.