Michigan Town Pulls Plug on Bogus Online Diplomas for Police Officers

If you are anything like me, your neatly framed, dusty college diploma is resting safely on the floor in the back of a hall closet. Or better yet, perhaps it is still in the canister that was handed to you as you crossed the stage to shake the hand of a graying university president. Not so for a group of Michigan police officers who purchased phony degrees from an online university!

Ruling on an appeal by Almeda University, an online university incorporated in the Caribbean island of Nevis, the Michigan Court of Appeals largely affirmed a trial court order granting summary judgment to the town of Fraser, Mich. (City of Fraser v. Alameda Univ., 2016 BL 10858 (Mich. Ct. App., 2016)).  The town alleged that the distance learning institution that offers “Life Experience Degrees” to prospective “students” violated the Michigan Authentic Credentials in Education Act by issuing bogus academic degrees to members of its police force.

Police Officers Bought Degrees to Get Raises

Eleven employees of Fraser, all of them police officers, obtained degrees from the online university between 2003 and 2009.  No officers were required to complete any classes, research or academic exams to earn these credentials. The online university billed applicants for a requested academic degree through its website at the rates of $99 for a bachelor’s degree, $795 for a master’s degree, or $1,495 for a doctorate degree, and it accepted credit card payments.

After obtaining their phony college degrees, the employees used the credentials to increase their salaries by as much as $1,000 to $3,000 annually.  The town of Fraser unwittingly increased the officers’ compensation and even reimbursed them for the cost of their educational expenses.

Long Arm of Michigan Law Reaches Online University in Caribbean

The Caribbean university challenged the trial court’s exercise of personal jurisdiction, arguing that the Michigan Authentic Credentials in Education Act requires fraudulent degrees to be issued or manufactured in Michigan, and that the state cannot control lawful behavior that occurs outside its borders.  

However, the Michigan Court of Appeals rejected that argument. The appeals court concluded that the university purposefully availed itself of the privilege of conducting activities in Michigan through its website interactions with state residents.  The court found that the online university accepted checks from Michigan applicants, and it mailed sham degrees directly to the home addresses of Michigan residents.  Moreover, the success stories of Michigan residents were highlighted on its website.

Statute of Limitations Bars all but One of Town’s Claims.

Upon review, the Michigan Court of Appeals held that the Michigan Authentic Credentials in Education Act contains a six-year statute of limitations. The court found that the statute of limitations barred all but one of the city of Fraser’s claims against Almeda, and it reduced a damages award to the city from $600,000 to $100,000.

Get up-to-date news and expert analysis from respected practitioners and Bloomberg BNA's legal editors, and practical research tools with a free trial to the Labor & Employment Law Resource Center .