Cleland v. National College of Business

Background

A for-profit proprietary college (the National College of Business) and several veterans challenged two rules that limit GI Bill educational payments. One rule bars benefits if more than 85% of a course’s students are subsidized by VA payments; the other bars benefits for courses offered less than two years at remote branches. A federal district court found the rules unconstitutional and enjoined their enforcement.

Reasoning

The Supreme Court reversed the district court. It reviewed Congress’ long history of tailoring these rules to prevent abuses—like schools recruiting veterans solely to collect federal funds—and concluded the limits were rational responses to those problems. The Court said Congress need not apply identical limits to every federal education program before addressing abuse in the GI Bill, and that imperfect classifications do not automatically violate the Constitution.

Real world impact

As a practical matter, the ruling lets the VA enforce the 85-15 enrollment limit and the two-year rule. That will make it harder for schools that rely heavily on veterans to get federal payments, and it may push veterans toward established programs or leave some without nearby qualifying options. The Court also stressed that Congress’ choices about how to prevent abuse deserve judicial deference unless they are clearly arbitrary.

Dissents or concurrances

Justice Marshall wrote separately, stating he believed significant due process questions existed and would have taken the case for full argument rather than deciding it on the papers.