1

THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS

NORTHERN DIVISION

OMAR HERNANDEZ, 

individually and on behalf of all 

others similarly situated,

 Plaintiff,

 v.

ILLINOIS INSTITUTE OF 

TECHNOLOGY,

Defendants.

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NO. 1:20-CV-3010

JUDGE:_________________

CLASS ACTION COMPLAINT AND JURY TRIAL DEMAND

Plaintiff Omar Hernandez (“Plaintiff”) by and through undersigned counsel, brings this 

action against Illinois Institute of Technology (“Defendant” or the “Institute”) on behalf of 

himself and all others similarly situated, and makes the following allegations based upon 

information, attorney investigation and belief, and upon Plaintiff’s own knowledge:

PRELIMINARY STATEMENT

1. Plaintiff brings this case as a result of Defendant's decision to close campus, 

constructively evict students, and transition all classes to an online/remote format as a 

result of the Novel Coronavirus Disease (“COVID-19”). 

2. While closing campus and transitioning to online classes was the right thing for 

Defendant to do, this decision deprived Plaintiff and the other members of the Class from 

recognizing the benefits of in-person instruction, access to campus facilities, student 

activities, and other benefits and services in exchange for which they had already paid 

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fees and tuition.

3. Defendant has either refused to provide reimbursement for the tuition, fees and other 

costs that Defendant is no longer providing, or has provided inadequate and/or arbitrary 

reimbursement that does not fully compensate Plaintiff and members of the Class for 

their loss.

4. This action seeks refunds of the amount Plaintiff and other members of the Class are

owed on a pro-rata basis, together with other damages as pled herein.

PARTIES

5. Defendant Illinois Institute of Technology is an institution of higher learning located in 

Chicago, State of Illinois.

6. Upon information and belief, Defendant has an estimated endowment of approximately 

$242.9 Million.1

7. Moreover, upon information and belief, Defendant is eligible to receive federal stimulus 

under the CARES Act. The Act directs that approximately 14 billion dollars be 

distributed to colleges and universities based upon enrollment and requires that 

institutions must use at least half of the funds they receive to provide emergency financial 

aid grants to students for expenses related to the disruption of campus operations due to 

COVID-19.

8. Plaintiff is an individual and a resident and citizen of the state of Illinois.

9. Plaintiff was enrolled in Defendant's graduate program, studying I.T. Management.

10. Plaintiff has paid substantial tuition for the Spring 2020 semester either out of pocket or 

by utilizing student loan financing, or otherwise.

 

1https://web.iit.edu/sites/web/files/departments/controller/pdfs/Fiscal%20Year%202019%20Financial%20Statement

s.pdf

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11. There are hundreds, if not thousands, of institutions of higher learning in this country.

12. Some institutions of higher learning provide curriculum and instruction that is offered on 

a remote basis through online programming which do not provide for physical attendance 

by the students.

13. Defendant's institution offers in person, hands on curriculum.

14. Plaintiff and members of the Proposed Tuition Class did not choose to attend another 

institution of higher learning, or to seek an online degree, but instead chose to attend 

Defendant's institution and enroll on an in-person basis.

15. Defendant markets the on campus experience as a benefit of enrollment, suggesting that 

their hands-on learning approach is “one of a kind” and forms the foundation of their 

educational approach:

2 3

16. Common sense would dictate that the level and quality of instruction an educator can 

provide through an online format is lower than the level and quality of instruction that 

 

2 https://www.iit.edu/

3 https://www.iit.edu/academics/active-learning

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can be provided in person.

17. Moreover, the true college experience encompasses much more than just the credit hours 

and degrees. The college experience consists of:

i. Face to face interaction with professors, mentors, and peers;

ii. Access to facilities such as computer labs, study rooms, laboratories, libraries, etc;

iii. Student governance and student unions;

iv. Extra-curricular activities, groups, intramurals, etc;

v. Student art, cultures, and other activities;

vi. Social development and independence;

vii. Hands on learning and experimentation; and

viii. Networking and mentorship opportunities.

18. Plaintiff’s education has changed from in-person hands on learning to online instruction.

19. Plaintiff’s online instruction is not commensurate with the same classes being taught in 

person.

20. In addition to tuition, Plaintiff was required to pay and did pay certain mandatory fees, 

including but not limited to an activity fee and a student services fee.

21. The activity fee is a mandatory fee charged to all students at Defendant’s institution, 

including graduate and undergraduate students, and full and part time students; except

that said fee is not charged to students enrolled in the law school.4

22. The school advertises the activity fee as “a mandatory fee that assists programs directly 

related to campus activities in conjunction with student organizations...[including] 

student organizations' operational, programming, and conference budgets as well as 

 

4 See, generally, https://web.iit.edu/student-accounting/tuition-fees/current-tuition

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large-scale campus events.”5

23. As a result of restricting students from campus, Defendant is no longer offering the 

services for which this fee was charged. Campus activities have been cancelled; student 

organizations are no longer offering campus programming, nor are they permitted to 

travel to or host conferences; and all large-scale campus events have been cancelled and 

prohibited.

24. Student’s at Defendant’s law school do not pay the activity fee, but rather pay a different 

fee called a student activity fee.6

25. This student activity fee is advertised as a fee providing “funding for major speakers, and 

for all other organizations and activities.”7

26. As a result of restricting students from campus, Defendant is no longer providing its law 

students with speakers or other activities for which this fee was charged.

27. The student services fee is a mandatory fee charged to all students at Defendant’s 

institution, including graduate and undergraduate students, and full and part time 

students; except that said fee is not charged to students enrolled in the law school or the 

Institute of Design.

8

28. The student services fee is advertised as “a mandatory fee that supports many on-campus 

departments such as Athletics, Paul V. Galvin Library, Career Services, and Technology 

Services.”

9

29. As a result of restricting students from campus, Defendant is no longer offering the 

 

5 https://web.iit.edu/student-accounting/tuition-fees/mandatory-and-other-fees

6 https://www.kentlaw.iit.edu/current-students/tuition-and-financial-assistance/tuition-and-fees/archives/jd-tuitionand-fees-2019-20

7

Id.

8 See, generally, https://web.iit.edu/student-accounting/tuition-fees/current-tuition

9 https://web.iit.edu/student-accounting/tuition-fees/mandatory-and-other-fees#student-service-fee

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services for which this fee was intended to cover, namely athletic functions, and access to 

campus libraries, computer labs, and internet networks.

30. Defendant charges students in its school of business a separate mandatory fee called a 

professional co-curricular fee.10

31. This fee is advertised as a mandatory fee supporting “co-curricular programs that enhance 

students' academic experience and increase their career readiness.”

11

32. As a result of restricting students from campus, Defendant is no longer providing access 

to such programs.

33. Finally, Defendant charges a studio fee for all students enrolled in the Institute of Design 

program(s).12

34. As a result of restricting students from campus, these studios are no longer available for 

use by such students.

35. In addition to the above referenced mandatory fees, Defendant charges a myriad of other 

program-specific and access based fees, including without limitation, a parking fee for 

students desiring to park on campus.

JURISDICTION AND VENUE

36. This Court has jurisdiction over this action pursuant to the Class Action Fairness Act 

(“CAFA”), 28 U.S.C. § 1332(d), because at least one class member is of diverse 

citizenship from one Defendant, there are more than 100 Class members, and the 

aggregate amount in controversy exceeds $5 million, exclusive of interest and costs.

37. This Court has personal jurisdiction over Defendant because Defendant is domiciled in 

Illinois and conducts business in Illinois.

 

10 https://web.iit.edu/student-accounting/tuition-fees/current-tuition/stuart-school-business

11 https://web.iit.edu/student-accounting/tuition-fees/mandatory-and-other-fees#co-curricular-fee

12 https://web.iit.edu/student-accounting/tuition-fees/current-tuition/institute-design

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38. Venue is proper in this District under 28 U.S.C. § 1391(b) because a substantial part of 

the events or omissions giving rise to the claims occurred in this District, and because 

Defendant is a corporate body domiciled and doing business in this District. 

FACTUAL ALLEGATIONS

39. Upon information and belief, Defendant’s Spring term began with the first day of classes 

on or about January 13, 2020.13

40. Upon information and belief, Defendant’s Spring term was scheduled to conclude with 

the last day of examinations on or about May 9, 2020 and commencement ceremonies on 

May 16, 2020.14

41. Defendant’s Spring break began on or about March 16, 2020 and was supposed to end on 

or about March 21, 2020, with students to return for in person classes beginning March 

23, 2020.15

42. However, as a result of the COVID-19 pandemic, Defendant announced on March 12, 

2020 that it was moving all classes online following the return from Spring Break.16

43. In this announcement, Defendant “strongly encourage[ed] students planning to depart for 

spring break to make plans not to return to campus until further notice and finish the 

semester from home, if at all possible.”

17

44. On March 12, 2020, Defendant announced that all university-sponsored air and train 

travel was being suspended immediately, including class activities, athletic endeavors, 

and conference attendance.18

 

13 https://web.iit.edu/registrar/academic-calendar

14 Id.

15 Id.

16 https://www.iit.edu/COVID-19

17 Id.

18 Id.

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45. On March 16, 2020, Defendant announced that neither its libraries nor the Keating Sports 

Center would re-open to students following Spring Break.19

46. On March 19, 2020, Defendant again issued a notice “strongly urging” students not to 

return following Spring Break, and noting, “[s]tudents who have absolutely no other 

option but to return to the university must understand that they will be returning to a very 

different campus environment.”

20

47. On March 20, 2020, Defendant announced that it would be moving nearly all classes to a 

pass/fail grading model.21 This varied significantly from similar institutions that allowed 

students the option, but did not require all students to universally switch to pass/fail 

grading.

48. This uniform policy operated to the detriment of many students.

49. Also on March 20, 2020, Defendant issued a notice that abandoned the notion of 

“strongly discouraging” students from returning to campus, and instead, outright 

prohibited students from returning to campus, absent extraordinary circumstances.22

50. For students who were permitted to remain on campus, Defendant restricted their 

movements to the dorms, dining facilities, and travel for essential services.23

51. Based on the dates set forth above, upon information and belief, Defendant’s move to 

online classes and constructive eviction of students on March 23, deprived Plaintiffs and 

other members of the Classes from access to campus and in person instruction for 

approximately 40% of the semester for which they had contracted.

52. Although Defendant is still offering some level of academic instruction via online 

 

19 Id.

20 Id.

21 Id.

22 Id.

23 Id.

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classes, Plaintiffs and members of the proposed Tuition Class have been and will be 

deprived of the benefits of on campus learning as set forth more fully above.

53. Moreover, the value of any degree issued on the basis of online or pass/fail classes will 

be diminished for the rest of their lives.

54. Likewise, Plaintiffs and members of the proposed Fees Class have been and will be 

deprived of utilizing services for which they have already paid, such as access to campus 

facilities, and other opportunities.

55. Nonetheless, Defendant has refused and continues to refuse to offer any pro-rated 

discounts or refunds on the tuition and mandatory fees that Students have already prepaid:24

CLASS ACTION ALLEGATIONS

56. Plaintiff brings this action on behalf of himself and as a class action, pursuant to the 

provisions of Rule 23 of the Federal Rules of Civil Procedure on behalf of the following 

Classes:

The Tuition Class:

All people who paid tuition for or on behalf of students enrolled in classes at the 

Institute for the Spring 2020 semester who were denied live in-person instruction 

and forced to use online distance learning platforms for the latter portion of that 

semester.

The Fees Class:

All people who paid fees for or on behalf of students enrolled in classes at the 

Institute for the Spring 2020 semester.

 

24 https://web.iit.edu/financial-aid/covid-19

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57. Excluded from the Classes are The Board of Trustees of the Illinois Institute of 

technology (or similar governing body) and any of their respective members, affiliates, 

parents, subsidiaries, officers, directors, employees, successors, or assigns; and the 

judicial officers, and their immediate family members, and Court staff assigned to this 

case. Plaintiffs reserve the right to modify or amend the Class definitions, as appropriate, 

during the course of this litigation.

58. Certification of Plaintiff’s claims for class-wide treatment is appropriate because Plaintiff 

can prove the elements of his claims on a class-wide basis using the same evidence as 

would be used to prove those elements in individual actions alleging the same claims.

59. This action has been brought and may be properly maintained on behalf of the Class 

proposed herein under Federal Rule of Civil Procedure 23.

Numerosity: Fed. R. Civ. P. 23(a)(1)

60. The members of the Class are so numerous and geographically dispersed that individual 

joinder of all Class members is impracticable. Plaintiff is informed and believes there are 

thousands of members of the Class, the precise number being unknown to Plaintiff, but 

such number being ascertainable from Defendant's records. Class members may be 

notified of the pendency of this action by recognized, Court-approved notice 

dissemination methods, which may include U.S. mail, electronic mail, internet postings, 

and/or published notice.

Commonality and Predominance: Fed. R. Civ. P. 23(a)(2)

61. This action involves common questions of law and fact, which predominate over any 

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questions affecting individual Class members, including, without limitation:

i. Whether Defendant engaged in the conduct alleged herein;

ii. Whether there is a difference in value between online distance learning and live 

in-person instruction;

iii. Whether Defendant breached its contracts with Plaintiff and the other members of 

the Tuition Class by retaining the portion of their tuition representing the 

difference between the value of online distance learning and live in-person 

instruction;

iv. Whether Defendant was unjustly enriched by retaining tuition payments of 

Plaintiff and the Tuition Class representing the difference between the value of 

online distance learning and live in-person instruction;

v. Whether Defendant breached its contracts with Plaintiff and the other members of 

the Fees Class by retaining fees without providing the services the fees were 

intended to cover;

vi. Whether Defendant was unjustly enriched by retaining fees of Plaintiff and the

other members of the Fees Class without providing the services the fees were 

intended to cover;

vii. Whether certification of any or all of the classes proposed herein is appropriate 

under Fed. R. Civ. P. 23;

viii. Whether Class members are entitled to declaratory, equitable, or injunctive relief, 

and/or other relief; and

ix. The amount and nature of relief to be awarded to Plaintiff and the other Class 

members.

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Typicality: Fed. R. Civ. P. 23(a)(3)

62. Plaintiff’s claim is typical of the other Class member’s claims because, among other 

things, all Class members were similarly situated and were comparably injured through 

Defendant's wrongful conduct as set forth herein.

Adequacy: Fed. R. Civ. P. 23(a)(4)

63. Plaintiff is an adequate Class representative because his interests do not conflict with the 

interests of other members of the Class he seeks to represent. Plaintiff has retained 

counsel competent and experienced in complex litigation; and Plaintiff intends to 

prosecute the action vigorously. The Class’s interests will be fairly and adequately 

protected by Plaintiff and his counsel.

Superiority: Fed. R. Civ. P. 23(b)(3)

64. A class action is superior to any other available means for the fair and efficient 

adjudication of this controversy, and no unusual difficulties are likely to be encountered 

in the management of this class action. The damages or other financial detriment 

suffered by Plaintiff and other Class members are relatively small compared to the 

burden and expense that would be required to individually litigate their claims against

Defendant, so it would be impracticable for members of the Class to individually seek 

redress for Defendant's wrongful conduct.

65. Even if Class members could afford individual litigation, the Court system likely could 

not. Individualized litigation creates a potential for inconsistent or contradictory 

judgments, and increases the delay and expense to all parties and the court system. By 

contrast, the class action device presents far fewer management difficulties and provides 

the benefits of single adjudication, economy of scale, comprehensive supervision by a 

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single court, and finality of the litigation.

Certification of Specific Issues: Fed. R. Civ. P. 23(c)(4)

66. To the extent that a Class does not meet the requirements of Rules 23(b)(2) or (b)(3), 

Plaintiff seeks the certification of issues that will drive the litigation toward resolution.

Declaratory and Injunctive Relief: Fed. R. Civ. P. 23(b)(2)

67. The Institute has acted or refused to act on grounds generally applicable to Plaintiff and 

the other Class members, thereby making appropriate final injunctive relief and 

declaratory relief, as described herein, with respect to the Class members as a whole.

FOR A FIRST COLLECTIVE CAUSE OF ACTION

BREACH OF CONTRACT

(Plaintiff and Other Members of the Tuition Class)

68. Plaintiff incorporates by reference all preceding allegations as though fully set forth 

herein.

69. Plaintiff brings this count on behalf of himself and other members of the Tuition Class.

70. Plaintiff and the Tuition Class entered into contracts with the Institute which provided 

that Plaintiff and other members of the Tuition Class would pay tuition for or on behalf of 

students and, in exchange, the Institute would provide live in-person instruction in a 

physical classroom.

71. Plaintiff and other members of the Tuition Class fulfilled their end of the bargain when 

they paid tuition for the Spring 2020 semester either out-of-pocket or by using student 

loan financing, or otherwise.

72. The Institute breached the contract with Plaintiff and the Tuition Class by moving all 

classes for the Spring 2020 semester to online distance learning platforms, without 

reducing or refunding tuition accordingly.

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73. The Institute retained tuition monies paid by Plaintiff and other members of the Tuition 

Class, without providing them the full benefit of their bargain.

74. Plaintiff and other members of the Tuition Class have suffered damage as a direct and 

proximate result of Defendant's breach, including but not limited to being deprived of the 

value of the services the tuition was intended to cover, namely live in-person instruction 

in a physical classroom.

75. As a direct and proximate result of Defendant's breach, Plaintiff and the Tuition Class are 

legally and equitably entitled to damages, to be decided by the trier of fact in this action, 

to include but not be limited to disgorgement of the difference between the value of the 

online learning which is being provided versus the value of the live in-person instruction 

in a physical classroom that was contracted for.

FOR A SECOND COLLECTIVE CAUSE OF ACTION

UNJUST ENRICHMENT

(Plaintiff and Other Members of the Tuition Class)

76. Plaintiff incorporates by reference all preceding allegations as though fully set forth 

herein.

77. Plaintiff brings this count on behalf of himself and other members of the Tuition Class.

78. This claim is pled in the alternative to, and to the extent it is determined a contract does 

not exist or otherwise apply to, the contract-based claim set forth in the First Cause of 

Action above.

79. The Institute has received a benefit at the expense of Plaintiff and other members of the 

Tuition Class to which it is not entitled.

80. Plaintiff and other members of the Tuition Class paid substantial tuition for live in-person 

instruction in physical classrooms and did not receive the full benefit of the bargain.

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81. Plaintiff and other members of the Tuition Class conferred this benefit on Defendant

when they paid the tuition.

82. Defendant has realized this benefit by accepting such payment.

83. Defendant has retained this benefit, even though Defendant has failed to provide the 

services for which the tuition was collected, making Defendant's retention unjust under 

the circumstances. 

84. Equity and good conscience requires that the Institute return a portion of the monies paid 

in tuition to Plaintiff and other members of the Tuition Class.

85. Defendant should be required to disgorge this unjust enrichment.

FOR A THIRD COLLECTIVE CAUSE OF ACTION

BREACH OF CONTRACT

(Plaintiff and Other Members of the Fees Class)

86. Plaintiff incorporates by reference all preceding allegations as though fully set forth 

herein.

87. Plaintiff brings this count on behalf of himself and other members of the Fees Class.

88. Plaintiff and the Fees Class entered into contracts with the Institute which provided that 

Plaintiff and other members of the Fees Class would pay certain fees for or on behalf of 

students and, in exchange, the Institute would provide services related to those fees, such 

as access to student activities, athletics, wellness centers, libraries, etc.

89. Plaintiff and other members of the Fees Class fulfilled their end of the bargain when they 

paid these fees for the Spring 2020 semester either out-of-pocket or by using student loan 

financing, or otherwise.

90. The Institute breached the contract with Plaintiff and the Fees Class by moving all classes 

for the Spring 2020 semester to online distance learning platforms, constructively 

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evicting students from campus, and closing most campus buildings and facilities.

91. The Institute retained fees paid by Plaintiff and other members of the Fees Class, without 

providing them the full benefit of their bargain.

92. Plaintiff and other members of the Fees Class have suffered damage as a direct and 

proximate result of Defendant's breach, including but not limited to being deprived of the 

value of the benefits and services the fees were intended to cover.

93. As a direct and proximate result of Defendant's breach, Plaintiff and the Fees Class are 

legally and equitably entitled to damages, to be decided by the trier of fact in this action, 

to include but not be limited to disgorgement of the pro-rata amount of fees that was 

collected but for which services were not provided.

FOR A FOURTH COLLECTIVE CAUSE OF ACTION

UNJUST ENRICHMENT

(Plaintiff and Other Members of the Fees Class)

94. Plaintiff incorporates by reference all preceding allegations as though fully set forth 

herein.

95. Plaintiff brings this count on behalf of himself and other members of the Fees Class.

96. This claim is pled in the alternative to, and to the extent it is determined a contract does 

not exist or otherwise apply to, the contract-based claim set forth in the Third Cause of 

Action above.

97. The Institute has received a benefit at the expense of Plaintiff and other members of the 

Fees Class to which it is not entitled.

98. Plaintiff and other members of the Fees Class paid substantial student fees for on campus 

benefits and services and did not receive the full benefit of the bargain.

99. Plaintiff and other members of the Fees Class conferred this benefit on Defendant when 

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they paid the fees.

100. Defendant has realized this benefit by accepting such payment.

101. Defendant has retained this benefit, even though Defendant has failed to provide 

the services for which the fees were collected, making Defendant's retention unjust under 

the circumstances. 

102. Equity and good conscience requires that the Institute return a pro-rata portion of 

the monies paid in fees to Plaintiff and other members of the Fees Class.

103. Defendant should be required to disgorge this unjust enrichment.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff, individually and on behalf of members of the Class(es), pray for 

judgment in their favor and against Defendant as follows:

a. Certifying the Classes as proposed herein, designating Plaintiff as Class 

representative, and appointing undersigned counsel as Class Counsel;

b. Declaring that Defendant is financially responsible for notifying the Class 

members of the pendency of this action;

c. Declaring that Defendant has wrongfully kept monies paid for tuition and fees;

d. Requiring that Defendant disgorge amounts wrongfully obtained for tuition and 

fees;

e. Awarding injunctive relief as permitted by law or equity, including enjoining 

Defendant from retaining the pro-rated, unused monies paid for tuition and fees;

f. Scheduling a trial by jury in this action;

g. Awarding Plaintiff’s reasonable attorney’s fees, costs and expenses, as permitted 

by law;

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h. Awarding pre and post judgment interest on any amounts awarded, as permitted 

by law; and

i. Awarding such other and further relief as may be just and proper.

DEMAND FOR JURY TRIAL

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands trial by 

jury in this action of all issues so triable.

Dated May 20, 2020

Respectfully Submitted,

ANASTOPOULO LAW FIRM, LLC

BY __/s/ Roy T. Willey, IV _

Roy T. Willey, IV

Bar Number: 101010

Eric M. Poulin (Bar Admission Pending)

32 Ann Street

Charleston, SC 29403

P: (843) 614-8888

F: (843) 494-5536

Email: roy@akimlawfirm.com

eric@akimlawfirm.com

ATTORNEYS FOR PLAINTIFF(S)

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