A recent court decision has put a spotlight on the legal complexities surrounding university fellowship agreements. The case involves a former student who filed a complaint against a major university, claiming breach of contract over two fellowship awards. On December 17, 2025, Loic Tagne filed an appeal in the North Carolina Court of Appeals against The University of North Carolina at Chapel Hill after his initial complaint was dismissed by Judge Allen Baddour in Orange County Superior Court.
The dispute centers around two fellowships awarded to Tagne upon his acceptance into the full-time Master of Business Administration program at Kenan-Flagler Business School. In December 2022, Tagne received an admission letter notifying him of the Consortium for Graduate Student in Management (CGSM) Fellowship, which covered tuition and fees but excluded optional charges like health insurance and housing. In June 2023, he was informed of another award—the Bank of America (BofA) MBA Fellowship—which also covered tuition and fees but included an additional $5,000 annual stipend.
Tagne’s complaint alleged that the university breached these contracts by failing to refund him the full value of one scholarship, amounting to $71,000 per academic year for out-of-state students. He argued that he was entitled to this sum over both years of his MBA program. However, when Tagne amended his complaint on May 30, 2024, he named The University of North Carolina at Chapel Hill as the defendant instead of its Board of Governors.
The university countered with a motion to dismiss based on sovereign immunity and other jurisdictional grounds. They contended that both fellowship letters clearly stated their purpose: to cover tuition and fees directly through disbursements to the University’s Cashier’s Office. The second letter merely updated the funding source and added a stipend without altering the core terms.
During a hearing on November 12, 2024, Judge Baddour sided with the university’s interpretation. He ruled that since one fellowship already covered all tuition and fees, there was no obligation for additional payment under another award. Thus, he granted the motion to dismiss Tagne’s claims due to insufficient grounds for breach of contract.
Tagne appealed this decision, questioning whether the trial court erred in its dismissal based on failure to state a claim upon which relief could be granted. However, appellate judges found no ambiguity in the fellowship terms—both were intended solely for covering tuition and fees plus a stipend—and upheld that there was no breach as alleged by Tagne.
Representing Tagne is Matthew W. Buckmiller from Buckmiller & Frost PLLC while Anne Phillips Martin serves as Special Deputy Attorney General for UNC-Chapel Hill under Attorney General Jeff Jackson’s office. The case ID is COA25-296 with Judges Tyson and Arrowood concurring in affirming Judge Baddour’s original ruling.
Source: COA25296_Tagne_v_The_University_of_North_Carolina_at_Chapel_Hill_Opinion_North_Carolina_Court_of_Appeals.pdf
