In Harris v. Adams, the School Had Corroborated the AI Flag Before It Disciplined

Harris v. Adams and Matter of Newby v Adelphi Univ. A third matter, in Michigan, is a filed complaint rather than a finding. A federal magistrate judge in Massachusetts denied the parents' motion for a preliminary injunction in Harris v. Adams on 20 November 2024 ¹. A New York judge reversed an Adelphi University integrity penalty on 28 January 2026 and ordered the record expunged ²³⁴.

Jurisdiction decides how far any of it travels. Harris v. Adams is a federal district court applying the Fourteenth Amendment to a public high school ¹. Matter of Newby v Adelphi Univ. is a state trial court deciding a CPLR article 78 petition against a private university ². Neither binds another school: one is a preliminary ruling of a single federal trial court, the other a state trial court decision. Two rulings are a thin evidence base, and this page doesn't claim they're the only ones.

What carries over is the fact pattern rather than the result. In Harris v. Adams the court noted that, before imposing any consequence, the school took multiple steps to confirm the AI use ¹; the denial itself rested on the parents being unlikely to succeed on their due process claims ¹. Adelphi is murkier. The published reporting gives the result and the judge's words but not the full ground, and Plagiarism Today's Jonathan Bailey reads it as a dispute over what happened rather than over the integrity standard ³.

Corroboration the school could name, and an admission. Turnitin flagged parts of a draft script. The teacher then opened the document's revision history, which showed roughly 52 minutes of work where other students spent seven to nine hours ¹. She ran two further tools the order describes as AI detection tools, Draft Back and Chat Zero ¹. The first and third footnotes cited books that don't exist ¹. Then the student admitted using Grammarly to generate portions of the script ¹.

The court did not rule on the software. Counsel questioned the accuracy of those tools at the hearing. The court answered in a footnote that there was no dispute that AI had been used, pointing to the plaintiffs' own filing ¹, and made no finding on how accurate the tools are.

The handbook in force that year never mentioned artificial intelligence ¹. At the preliminary injunction stage the court found the parents unlikely to succeed on the argument that the handbook gave no notice: it prohibited cheating and plagiarism, the student had sat a lesson that said AI use must be cited, and the court cited authority that a school may punish an offense no prior rule specifically forbids ¹. The following year's handbook added an explicit AI clause, which the court treated as a subsequent remedial measure rather than proof the old wording had failed ¹.

On process the court assumed, for present purposes, that the Goss v. Lopez standard for a suspension of ten days or less applied, though the student was not suspended ¹. That standard asks for notice of the accusation and a chance to answer it ¹. The student met the teacher and the social studies director on 20 and 21 December 2023 and was shown the revision-history and Turnitin results ¹, and his parents were offered a meeting of their own on 22 December ¹. On the record to date, the court found the school met or exceeded it ¹.

The consequences were a zero on two of the assignment's six components and a Saturday detention in January 2024 ¹. The National Honor Society turned him down in March. That later became a deferral, and he was admitted in October 2024 ¹.

Less than the headlines suggest: the reporting gives the result and the judge's words, not the full reasoning. An instructor ran an essay for World Civilizations 1 through Turnitin's AI detector. It flagged the essay as wholly AI-generated, and the student got a zero ³. The work was deemed fraudulent and an anti-plagiarism course was required, and a second offense could have meant suspension or expulsion ³⁴.

Orion Newby had been tutored through Adelphi's Bridges program, which supports students with learning and neurological conditions, and he said so at the time ⁴.

Plagiarism Today reports that the instructor and the school declined to re-examine the allegation. It also reports two additional AI checks that read the paper as human-written ³. Its author, Jonathan Bailey, judged it unlikely that the university interviewed the tutors or examined the working files ³. That's a commentator's inference, not a finding in the record.

Justice Randy Sue Marber decided the petition on 28 January 2026, published as Matter of Newby v Adelphi Univ., 89 Misc 3d 828 ². As reported, the judge found the allegations completely false and the punishment "without valid basis and devoid of reason", reversed the discipline and ordered the record expunged ³⁴. The university said it was evaluating the decision ³⁴.

One caution about this page's own sourcing: the opinion's text couldn't be read for it. The Leagle copy shows only the caption, and the New York Official Reports page didn't open. So the caption, court, index number and date come from the Leagle listing ², and everything about the outcome comes from contemporaneous reporting ³⁴.

Corroboration. The Massachusetts record carries four checks as the order describes them, fabricated citations and then an admission, all before any consequence landed ¹. The Adelphi penalty, as reported, was a zero plus a required course ³⁴; the instructor and the school declined to re-examine the allegation, and the student's internal appeal was denied ³. What Adelphi's file held is not reported.

CUNY publishes a neighboring step in one sentence: a faculty member who suspects a violation reviews the facts and circumstances with the student first, whenever that is feasible ⁶. It is a conversation rather than a corroboration rule, and a policy that wants the charge to name its corroborating evidence has to say so itself. Where a CUNY student contests the allegation, the hearing procedures give at minimum written notice of the charges, the right to appear, and the right to present witness statements or call witnesses ⁶.

A reading is a reason to look rather than a conclusion, and why a score alone cannot support a finding makes that case. The clause that authorizes the charge belongs in the integrity policy itself, drafted as in the AI clause an integrity policy needs. After that, a student's route runs through an appeals process built to survive review.

A finding kept in a student's file is the kind of record addressed by the amendment procedure in FERPA, the United States federal law binding schools that receive federal education funds ⁷⁸. Under 34 CFR 99.21, a parent or eligible student whose request to amend a record the school has declined can ask for a hearing on the ground that the record is inaccurate, misleading, or in violation of the student's privacy rights ⁷. There's a limit. The Department of Education's guidance says the procedure can correct facts that are inaccurately recorded, but not a grade, an opinion, or a substantive decision such as a disciplinary ruling ⁸. If the record stands after that hearing, the parent or eligible student may put a written statement of disagreement in the file, and it travels with the record whenever the record is disclosed ⁷.

Nothing at all, which makes the Michigan matter the one to handle carefully. Reported on 23 February 2026, the complaint describes a student placed on disciplinary probation with a no-record grade ⁵. The instructor is alleged to have concluded three times that her work was machine-written. Those conclusions, the complaint says, rested on judgments about her writing style and on comparison outputs generated from her own outlines ⁵.

It also says she has generalized anxiety disorder and obsessive-compulsive disorder, and it seeks a disability-informed process ⁵. An administrator can build that process long before a court asks for it, and the pattern behind it is set out in what a detection policy owes neurodivergent students.

An allegation is not a finding, in either direction. A complaint doesn't establish that a detector erred, and a denied injunction doesn't establish that a detector works ¹⁵. This page records what two courts did with two records. It isn't legal advice, and a change to a discipline policy belongs with counsel.