No Preliminary Injunction for Yale MBA Student Suing Over Discipline for Alleged Use of AI on Exam
From today’s decision by Judge Sarah Russell (D. Conn.) in Rignol v. Yale Univ. (a case I first wrote about when Rignol’s attempt to sue pseudonymously was rejected):
Plaintiff Thierry Rignol is an entrepreneur and investor who enrolled as a part-time graduate student at the Yale School of Management (“SOM”) in 2023 as a member of the class of 2025. After a teaching assistant flagged one of his exams in the spring of 2024, SOM administrators conducted an investigation to determine whether Rignol violated examination rules by using generative artificial intelligence (“AI”). In the course of its investigation, SOM determined that Rignol was not forthcoming during the investigation and did use AI; SOM penalized Rignol by issuing him an F in the course and suspending him from classes for one year.
Rignol subsequently sought a preliminary injunction that would reinstate him as a student in good standing at SOM such that he could graduate with his classmates in the class of 2025 this spring. Because I conclude that Rignol has failed to make the threshold showing of irreparable harm, I deny Rignol’s motion for a preliminary injunction…
Here is an excerpt from the court’s long and detailed account of the factual allegations:
Thierry Rignol is an entrepreneur and investor. In his LinkedIn profile, which Defendants attach to their memorandum, Rignol describes himself as the founder of a “technology driven real estate and hospitality company” headquartered in Mexico and operating throughout the Americas. Rignol’s profile says his firm had 28 full-time workers as of the end of 2020. In addition to managing his own firm, Rignol serves as a director on the boards of several private enterprises. Rignol is a French national authorized to live and work in the United States on an investor visa.
Rignol, by the way, had also run for the French Parliament in 2017, and continues to have “political aspirations.”
Rignol’s exam was flagged by a teaching assistant on June 10, 2024. The teaching assistant noted that Rignol’s exam, “one of the highest scoring,” had “clocked in at 30 pages whereas almost all others were under 20.” While conceding it was theoretically possible to produce such an exam under timed conditions, the teaching assistant said that Rignol’s exam “length stood out relative to the others.” J. Rouwenhorst investigated further and shared his initial findings with Wendy Tsung, an SOM administrator responsible for overseeing the EMBA program. In his email to Tsung on June 11, 2024, Rouwenhorst said he had “serious concerns about violation of the exam rules, such as improper use of AI.” He noted that certain “answers to essay type questions on the exam score high on the likelihood of being AI generated using ChatGPTzero as a detection tool” and “[a]t least one answer shows substantial overlap with answers to simple prompts on ChatGPT.” Rouwenhorst asked that Tsung “refer this to the Honor Committee for further investigation.” …
Professor Choi was chair of the Honor Committee in the summer and fall of 2024. After Tsung shared Rouwenhorst’s email describing Rignol’s potential academic misconduct with him, Choi undertook an initial investigation to decide whether Rignol’s conduct was sufficiently serious to merit referral to the full Honor Committee. As part of that initial review, Choi sought to examine the native file of the document Rignol used to turn in the PDF containing his exam answers….
Tsung wrote to Rignol on July 30, 2024, noting that Choi was “requesting that you submit to us the word version of your submission version of the Sourcing and Managing Funds exam.” Rignol did not respond [and failed to respond to follow-up requests]…. Choi says that Rignol was the first student to decline to produce documents in his ten years serving on the Honor Committee. After this initial investigation, Choi referred Rignol to the full H
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