The U.S. Department of Education has dismissed with prejudice its proposed $37.7 million fine against Grand Canyon University. The May 2025 order from the agency’s Office of Hearings and Appeals states plainly that no findings were made against the university, its employees, or its contractors, and no penalties apply.
The original action, issued in October 2023, alleged that GCU substantially misrepresented the costs of certain doctoral programs to thousands of students. The department claimed that advertised ranges of $40,000 to $49,000 understated actual expenses because most students required additional continuation courses. GCU appealed immediately, arguing that its disclosures met or exceeded legal requirements and that continuation courses are standard across doctoral programs in higher education.
The dismissal rests on a joint stipulation. That document removes the case entirely rather than settling it. In administrative proceedings, dismissal with prejudice carries a specific weight: the matter cannot be reopened on the same grounds. The order confirms that the department has not established any violation of Title IV requirements.
GCU’s public statement noted that students receive detailed information on program length, credits, and costs throughout enrollment. The university pointed to reviews by its accreditor, the Higher Learning Commission, which described the disclosures as robust, and to an audit by the Arizona State Approving Agency that found no substantiated issues. Two federal courts had already rejected similar claims in a related student lawsuit.
The fine was the largest the department had ever proposed against a single institution. Its reversal under the subsequent administration drew attention to the original process. A department spokesperson stated that unlike the prior approach, the current one would not target institutions based on religious affiliation. GCU is a private Christian university in Phoenix.
Related actions provide additional context. The Federal Trade Commission filed a parallel complaint in 2023 that echoed the doctoral-cost allegations. A federal district court dismissed the claims against GCU itself in March 2025, finding the FTC lacked jurisdiction over the nonprofit entity. The case continues against Grand Canyon Education, the service provider, and against university president Brian Mueller in his capacity with that company. In August 2025 the FTC dismissed its complaint against all parties.
A separate Ninth Circuit ruling in late 2024 addressed GCU’s nonprofit status for federal student aid purposes. The court held that the department had applied an incorrect legal standard and remanded the matter. The IRS has treated GCU as a 501(c)(3) organization. These threads—doctoral disclosures, nonprofit classification, and regulatory enforcement—ran through multiple agencies and courts over several years.
Observers note that the administrative record now contains an explicit statement of no findings. That outcome limits what can be claimed about the original allegations. It does not, however, erase the costs of litigation or the reputational effects that accompanied the initial announcement. For institutions facing similar reviews, the sequence illustrates how appeals and parallel litigation can alter the final administrative posture.
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GCU continues to operate its doctoral programs and reports graduation data on its site. Between 2020 and 2024, 2,341 students completed dissertation-based doctorates, taking an average of 6.2 years and 11.2 continuation courses. Average tuition and fees paid, including those courses, reached $52,855. The university maintains that maximum Title IV-eligible credits and program requirements are clearly stated in enrollment materials.
The case closed without any admission or determination of liability. Future regulatory actions against the institution would need to rest on new evidence or different grounds. The joint stipulation leaves the record clear on that point.