Andrews et al. v. University of Virginia School of Law
323 U.Va. 115 (2019)
DESKINS, J., announced the unanimous opinion of the Court.
Today’s opinion seeks to resolve an increasingly frustrating issue continuously presented before the Court: the daily temperature of the Law School’s classrooms. A class of plaintiffs representing the Law School’s entire student body (especially people who seek to wear warm-weather clothes during the warm-weather months—not Canada Goose parkas, sweatshirts, gloves, or L.L. Bean’s flannel-lined jeans) alleges that the classrooms in the Law School “are too darn cold.” (Compl. ¶ 1.) Plaintiffs aver that the sub-room temperature[1] temperatures constitute a violation of their fundamental right to be free of physical distractions in class.[2]
FACTS
Generations of UVA Law students have complained about the extremely cold temperatures in the classrooms.[3] Their suffering has manifested itself in many physical symptoms: shivering, cold and clammy fingers that lead to a diminished ability to type efficiently and quickly on their laptops,[4] feeling so cold that they become unable to concentrate on the lecture, anxiety stemming from the status of their exposed toes[5] due to their decision to wear Chacos instead of insulated boots, and increased sensations of hopelessness beyond that experienced by a typical law student. Plaintiffs state that they have been forced to endure these practically-arctic conditions not only during normal class meetings but also during exams. They also note that some individuals among the various defendants seem more prone to creating these environments than others. Defendants insist that the “cool”[6] temperatures serve several goals: (1) they help keep students alert in class, (2) high air-conditioning bills help keep tuition high, and (3) the unpleasant temperatures give otherwise-socially-incompetent law students something to discuss with their peers.[7] After feeble attempts to convince seemingly supportive professors of their plight, but to no avail, Plaintiffs filed suit with this Court. They seek an order requiring that Defendants set all classroom air conditioning systems to room temperature (71 degrees Fahrenheit).
Analysis
The Court of Petty Claims previously dismissed this case, asserting that Plaintiffs did not have standing to bring their claim.[8] We disagree. Plaintiffs have CLEARLY[9] demonstrated standing. They could easily avoid their classroom shivers by keeping a sweatshirt, sweatpants, socks, mink coats,[10] and towel warmers + warm towels in their lockers to don upon entering the Law School. However, doing so would at least slightly inconvenience Plaintiffs, and because they want to “have it [their] way”[11] without actually doing anything to deserve such an outcome, their claim thus qualifies as petty.
Additionally, Defendants’ supposed justifications for “temperature situation” (as it has come to be known) all fail. As for the “alertness” justification, multiple members of this Court have very unpleasant memories of being both very sleepy and very cold in the Law School’s classrooms. Cold calls are bad enough when you’re sleepy! Why add cold classrooms to the mix? As the second justification, Lee v. The Law School, 323 U.Va 99 (2019),[12] makes clear that the Law School needs no real justification for tuition increases. It does whatever it wants. Thus, we call bullshit on this one. Plaintiffs should not have to suffer from both cold temperatures and unjustified, unannounced tuition increases. As for Defendants’ final proffered justification, we can assure them that nothing will save UVA Law students from their own inability to discuss anything other than what they learned (or did not learn) in a particular class, their irrelevant undergraduate accomplishments, how much they grew professionally at their summer job,[13] and their plans to clerk on the DC Circuit after graduation. KDon, there’s really no hope.
Plaintiffs have presented a truly sad state of affairs to the Court. Finding that Defendants have proffered no valid justifications for their actions, we hereby REVERSE the finding of the lower court, and we ORDER that Defendants operate the Law School’s HVAC system as to maintain a “room temperature”[14] temperature.
It is so ordered.
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lcd4ew@virginia.edu
[1] The Court defines “room temperature” using the Porridge standard first articulated in Goldilocks v. Bear Family, 436 F. Tal. 311-12 (Sty. Cir. 1918) (Declaring that an appropriate bowl of porridge is “not too hot, and not too cold”), which, according to the Justices, when applied to classroom temperatures, is exactly 71 degrees Fahrenheit.
[2] See David A. Harrison III Law Grounds Unofficial Bill of Rights. The fundamental right to be free from physical distractions enables students to spend more time and energy focusing on their cyber-based distractions, namely, Amazon and their iMessage conversation with that friend across the room.
[3] And by “generations,” we mean as far back as Fall 2017, but there might be earlier instances of which the Court has not yet been made aware.
[4] This Court looks favorably upon those professors who allow the use of laptops in class.
[5] While no instances of classroom-induced frostbite have been introduced before the Court thus far, in the Court’s view, it is only a matter of time.
[6] Their term, not ours.
[7] The Office of Private Practice has emphasized this point in particular, claiming that it helps prepare students for OGI.
[8] As a reminder, in this jurisdiction, Plaintiffs do not need to (1) have suffered an “injury in fact,” (2) show that the injury is fairly traceable to the challenged action of the defendant, or (3) show that it is likely, as opposed to merely speculative, that the injury will be redressed by a favorable decision. Plaintiffs need only demonstrate a petty claim.
[9] LRW professors will tell you not to use words like this in your memos and briefs. They assert that you need to show, not tell, your audience that you have a strong claim. They’re CLEARLY wrong.
[10] We know at least some students from the 1% here at UVA Law can actually afford these.
[11] The Court was recently made aware that Burger King ditched its famous slogan in 2014 for the overly-supportive “Be Your Way.” Yuck. We belatedly mourn this loss, and more importantly, we want to let Professor Collins know that this means his Burger King v. Rudzewicz joke about the slogan is going to start falling flat very soon.
[12] See Va. Law Weekly No. 2, p. 4 (2019).
[13] This makes the Court cringe.
[14] Just a reminder, this is 71 degrees Fahrenheit.