Our own Court of Appeals has also considered and rejected claims of educational malpractice. In Johnson v. Clark, 165 Mich. App. 366, 367; 418 N.W.2d 466 (1987), the plaintiff, who had dyslexia and, as a high school graduate, could only read at the fourth-grade level, sued his teachers and the school psychologist, principal, and administrator, alleging that the "defendants' failure to properly perform annual tests and evaluations required by . . . statute and regulations promulgated thereunder resulted in plaintiff's failure to learn that he suffered from dyslexia." The Court of Appeals affirmed the trial court's grant of summary disposition in favor of the defendants on the ground that there was no common-law duty requiring teachers to properly test and evaluate special education students.

Although Michigan recognizes a teacher's common-law liability for a student's injuries proximately caused by the teacher, public policy must be considered in determining to what type of actions that duty extends. Johnson v Clark, 165 Mich. App. 366, 369-370; 418 N.W.2d 466 (1987). Michigan law is clear that the duty does not extend to educational malpractice.

' " (quoting Page v. Klein Tools, Inc., 610 N.W. 2d 900, 906 (Mich. 2000) ))); Johnson v. Clark, 418 N.W. 2d 466 (Mich. Ct. App. 1987); Dallas Airmotive, 277 S.W. 3d 696; Christensen v. Southern Normal School, 790 So. 2d 252, 255 (Ala. 2001) (claim is barred by educational malpractice doctrine if the claims "require an analysis of the quality of education received"); Gupta v. New Britain General Hospital, 687 A.2d 111 (Conn. 1996) (claim based on institution's failure to provide "adequate training" was not cognizable); Lawrence v. Lorain County Community College, 713 N.E.2d 478 (Ohio Ct. App. 1998) (court would not recognize any claim that educational services were "substandard" or "inadequate"); Bittle v. Oklahoma City University, 2000 OK CIV APP 66 (Okla. Civ. App. 2000) (declining to recognize claim based on "inadequate or improper instruction:); Houston v. Mile High Adventist Academy, 846 F. Supp. 1449, 1455-56 (D. Colo. 1994) (claims that teachers were "not properly trained," and that "school failed to provide adequate instruction" were construed as educational malpractice and properly dismissed); Finstad v. Was

¶ 36 While Illinois has not addressed whether educational malpractice claims are cognizable, most jurisdictions that have considered the issue have found that educational malpractice claims are not cognizable. See, e.g., Glorvigen, 796 N.W.2d 541, 553 ("The bar on educational-malpractice claims recognizes that ‘[a]llowing individuals ... to assert claims of negligent instruction would avoid the practical reality that, in the end, it is the student who is responsible for his knowledge, including the limits of that knowledge.’ " (quoting Page v. Klein Tools, Inc., 461 Mich. 703, 610 N.W.2d 900, 906 (2000) )); Johnson v. Clark, 165 Mich.App. 366, 418 N.W.2d 466 (1987) ; Dallas Airmotive, 277 S.W.3d 696; Christensen v. Southern Normal School, 790 So.2d 252, 255 (Ala.2001) (claim is barred by educational malpractice doctrine if the claims "require an analysis of the quality of education received"); Gupta v. New Britain General Hospital, 239 Conn. 574, 687 A.2d 111 (1996) (claim based on institution's failure to provide "adequate training" was not cognizable); Lawrence v. Lorain County Community College, 127 Ohio App.3d 546, 713 N.E.2d 478 (1998) (court would not recognize any claim that educational services were "substandard" or "inadequate"); Bittle v. Oklahoma City University, 2000 OK CIV APP 66, 6 P.3d 509 (2000) (declining to recognize claim based on "inadequate or improper instruction"); Houston v. Mile High Adventist Academy, 846 F.Supp. 1449, 1455–56 (D.Colo.1994) (claims that teachers were "not properly trained," and that "school failed to provide adequate instruction" were construed as educational malpractice and properly dismissed); Finstad

' " (quoting Page v. Klein Tools, Inc., 610 N.W. 2d 900, 906 (Mich. 2000) ))); Johnson v. Clark, 418 N.W. 2d 466 (Mich. Ct. App. 1987); Dallas Airmotive, 277 S.W. 3d 696; Christensen v. Southern Normal School, 790 So. 2d 252, 255 (Ala. 2001) (claim is barred by educational malpractice doctrine if the claims "require an analysis of the quality of education received"); Gupta v. New Britain General Hospital, 687 A.2d 111 (Conn. 1996) (claim based on institution's failure to provide "adequate training" was not cognizable); Lawrence v. Lorain County Community College, 713 N.E.2d 478 (Ohio Ct. App. 1998) (court would not recognize any claim that educational services were "substandard" or "inadequate"); Bittle v. Oklahoma City University, 2000 OK CIV APP 66 (Okla. Civ. App. 2000) (declining to recognize claim based on "inadequate or improper instruction:); Houston v. Mile High Adventist Academy, 846 F. Supp. 1449, 1455-56 (D. Colo. 1994) (claims that teachers were "not properly trained," and that "school failed to provide adequate instruction" were construed as educational malpractice and properly dismissed); Finstad v. Was

' " (quoting Pagev. Klein Tools, Inc., 610 N.W. 2d 900, 906 (Mich. 2000))); Johnson v. Clark, 418 N.W.2d 466 (Mich. Ct. App. 1987); Dallas Airmotive, 277 S.W.3d 696; Christensen v. Southern Normal School, 790 So. 2d 252, 255 (Ala. 2001) (claim is barred by educational malpractice doctrine if the claims "require an analysis of the quality of education received"); Gupta v. New Britain General Hospital, 687 A.2d 111 (Conn. 1996) (claim based on institution's failure to provide "adequate training" was not cognizable); Lawrence v. Lorain County Community College, 713 N.E.2d 478 (Ohio Ct. App. 1998) (court would not recognize any claim that educational services were "substandard" or "inadequate"); Bittle v. Oklahoma City University, 2000 OK CIV APP 66, 6 P.3d 509 (Okla. Civ. App. 2000) (declining to recognize claim based on "inadequate or improper instruction:); Houston v. Mile High Adventist Academy, 846 F. Supp. 1449, 1455-56 (D. Colo. 1994) (claims that teachers were "not properly trained" and that "school failed to provide adequate instruction" were construed as educational malpractice and properly dismissed); Fins