The U.S. Supreme Court case Board of Curators of the University of Missouri et al. v. Horowitz involved a medical student, Horowitz, who was dismissed from school due to her lack of clinical competence and inability to meet professional standards despite repeated warnings and opportunities for improvement. The court had to decide whether this dismissal required a formal hearing under the Due Process Clause of the Fourteenth Amendment or if it could be considered an academic decision that did not require such procedural protections. In 1977, in an 8-1 ruling delivered by Justice Powell, the Supreme Court held that when a student is dismissed from an educational institution for academic reasons rather than disciplinary ones, they are not entitled to a hearing or other procedural safeguards guaranteed by the Due Process Clause because these decisions involve professional judgment which courts should respect and refrain from second-guessing.

In the dissenting opinion for Board of Curators of the University of Missouri v. Horowitz, Justice Marshall disagreed with the majority's decision that due process was not violated when a medical student was dismissed without a hearing. He argued that students should have some form of notice and opportunity to be heard before being expelled from an educational institution. The dismissal had significant impacts on her career and personal life, which warranted procedural protections under the Fourteenth Amendment’s Due Process Clause. Furthermore, he contended that academic dismissals are not fundamentally different from disciplinary ones; both involve fact-finding processes where errors can occur and thus require similar safeguards against arbitrary decisions by school officials.