Appellant
Selective Service System of the United States
Appellee
Minnesota Public Interest Research Group, et al.
Appellant's Claim
That section 12(f) of the Military Selective Service Act did not constitute abill of attainder or a violation of the Fifth Amendment protection against compelled self-incrimination.
Chief Lawyer for Appellant
Rex E. Lee, U.S. Solicitor General
Chief Lawyer for Appellee
William J. Keppel
Justices for the Court
Warren E. Burger (writing for the Court), Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist, John Paul Stevens, Byron R. White
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall (Harry A. Blackmun did not participate)
Place
Washington, D.C.
Date of Decision
5 July 1984
Decision
That section 12(f) of the Military Selective Service Act, which denied federal financial assistance to male students between the ages of 18 and 26 who hadnot registered for the draft, constituted neither a bill of attainder nor aviolation of appellees' Fifth Amendment privilege against compelled self-incrimination.
Significance
Selective Service v. Minnesota Public Interest Research Group raised issues which date back as far as the post-Civil War era of Reconstruction, when the 1867 cases Cummings v. Missouri and Ex parte Garland addressed concerns over the Bill of Attainder Clause of the Constitution. A billof attainder, as the Court had defined it in Nixon v. Administrator of General Services (1977), was "a law that legislatively determines guilt andinflicts punishment upon an identifiable individual without provision of theprotections of a judicial trial," thus unfairly subjecting an individual to judgment without the benefit of a genuine legal action. The case also established important distinctions regarding prohibitions against self-incriminationembodied in the Fifth Amendment.
Uncle Sam and Eligible Young Men
Under section 3 of the Military Selective Service Act, the president of the United States is empowered to require every male citizen and resident alien inthe country between the ages of 18 and 26 to register for military service under the draft. On 2 July 1980, President Jimmy Carter signed Presidential Proclamation No. 4771, which required all young men to register within 30 daysof their eighteenth birthday.
On 8 September 1982, Congress passed the Department of Defense AuthorizationAct of 1983, thereby adding section 12(f) to the Selective Service Act. Under12(f), eligible young male students who failed to register would be ineligible for federal financial assistance under Title IV of the Higher Education Act of 1965. Under section 12(f)(2), applicants for such assistance were required to file a statement with their college, university, or trade school showing that they had complied with the draft registration law. Clauses (3) and (4)of 12(f) further required the secretary of education, working with the director of Selective Service, to prescribe methods for verifying statements of compliance, and to issue regulations for implementation. In their final form, as issued on 11 April 1983, these regulations stipulated that no applicant could receive financial aid for higher education under Title IV unless he firstfiled a statement certifying that he had registered with the Selective Service or that, due to a specified reason such as a physical impairment which would prevent him from military service, he was exempt from the registration requirement. The provision did not require the applicant to state the date on which he had registered.
In November of 1982, an organization called the Minnesota Public Interest Research Group (MPIRG) filed a complaint with the U.S. District Court in Minnesota to enjoin, or stop, the federal government's operation of 12(f). The district court dismissed MPIRG for lack of standing, but did allow three anonymousstudents to stand in as plaintiffs in the case. The students, still operating under the MPIRG name and in conjunction with MPIRG counsel, held that theyresided in Minnesota; that they required financial aid to complete their education; that they intended to apply for such aid; and that though they were eligible for the draft, they had failed to register with the Selective Service.Later they consolidated their suit with that of three other anonymous youngmen making essentially the same claim.
In March of 1983, the district court granted a preliminary injunction restraining the Selective Service from enforcing section 12(f). The court's reasoning was twofold. First, it held that 12(f) was a bill of attainder, and thus "clearly singles out an ascertainable group based on past conduct" and "legislatively determines the guilt of this ascertainable group." Second, the court held that 12(f) violated the appellees' privilege against compelled self-incrimination as guaranteed under the Fifth Amendment, because it compelled students requesting financial aid to confess the crime of not having registered forthe draft.
On 16 June 1983, the district court issued a nationwide injunction against the enforcement of 12(f), but less than two weeks later, on 29 June, the U.S. Supreme Court stayed that order pending docketing and final disposition of theappeal. Filing amici curiae briefs urging affirmance of the lower court's ruling were individuals representing Swarthmore College and the University of Minnesota. The trustees of Boston University filed a brief urging reversal.
Questions of Punitive Intent and Compulsion
By a vote of 6-2 the Court reversed the ruling of the lower court. Chief Justice Burger, writing for the Court, addressed the two issues under debate: thebill of attainder question and the Fifth Amendment question. On both counts,he found 12(f) fully constitutional, an opinion in which Justices O'Connor,Rehnquist, Stevens, and White joined, and with which Powell concurred in partwhile concurring in the judgment. Justices Brennan and Marshall dissented, and though both filed opinions, the latter's was much longer and more forceful.
A bill of attainder, the Chief Justice held, quoting Nixon v. Administrator of General Services, was "a law that legislatively determines guilt andinflicts punishment upon an identifiable individual without provision of theprotections of a judicial trial." An example of a bill of attainder was a provision in the post-Civil War Constitution of Missouri, which prevented a person from entering a given profession unless he swore under oath that he had not "been a member of, or connected with, any order, society, or organizationinimical to the government of the United States." The law, which was clearlyintended to bar former supporters of the Confederate government from any rolein public life, was struck down in Cummings v. Missouri (1867), and the Court struck down a similar law in Ex parte Garland (1867).
Section 12(f), on the other hand, did not single out those who failed to register, or make them ineligible based on that past conduct. It did not requireregistration within the time period established by the Presidential Proclamation, nor did it deem late registrants ineligible for aid. Rather, it "clearlygives non-registrants 30 days after receiving notice that they are ineligible for Title IV aid to register for the draft and qualify for aid." Nor did itinflict punishment, at least as that term was understood in the Bill of Attainder Clause in the Constitution. "It does not even deprive appellees of Title IV benefits permanently," the Chief Justice wrote, "since it leaves open perpetually the possibility of qualifying for aid." In passing 12(f), Congresshad meant simply to "encourage registration" by those who were required to register and had not done so. It was not punitive in nature, but rather was intended to provide "a rational means to improve compliance with the registration requirements."
With regard to the Fifth Amendment privilege against compelled self-incrimination, Burger held that since a student who had not registered with the Selective Service would be bound to know that his application for financial aid would be denied, he was by no means under any "compulsion" to seek that aid. Inother words, applying for aid was a choice he would have to make of his own free will, and if he did not want to sign up for the draft, then he would haveto accept the consequences of that freely taken action--including the withholding of federal funds. As for the fact that a student who changed his mind and registered for the draft after all might be registering after the 30 day deadline, this too failed to constitute compulsory self-incrimination. The lawdid not require a student to inform officials at his school whether or not he had registered late, nor would lateness in registering disqualify a studentfrom applying for financial aid. Because the appellees had not attempted toregister, they "had no occasion to assert their Fifth Amendment privilege when asked to state their dates of birth . . . " Nor, finally, had the government threatened them with any consequences--short of not receiving a financial aid check--for their failure to comply. "Under these circumstances," Burger wrote, "appellees will not be heard to complain that 12(f) violates their FifthAmendment rights by forcing them to acknowledge during the draft process they have avoided that they are registering late."
Justice Powell concurred in part and concurred in the judgment. In his view,the bill of attainder issue could be settled much more easily than the Courthad disposed of it, simply by noting that 12(f) was not punitive legislation,a distinction established in Nixon v. Administrator of General Services. The Selective Service Act--and only that act--provided a punishment for the crime of failing to register for the draft. Section 12(f), by contrast, "authorizes no punishment in any normal or general acceptance of that familiarterm." Using much the same logic as the Court, but applying it more directly,Powell was saying that withholding a privilege is not the same thing as conferring a punishment. Far from authorizing punitive actions, section 12(f) "provides a benefit at the expense of taxpayers generally for those who requestand qualify for it." No one was compelled to receive it, nor was any minoritygroup forbidden from receiving it. Since he found that 12(f) was not punitive in purpose or effect, Powell held that it was unnecessary to address the other questions the Court had reviewed in examining the bill of attainder issue.
Marshall's Dissent: "A De Facto Classification Based on Wealth"
Justice Brennan issued a short dissenting opinion, wherein he stated that hewould affirm the lower court's judgment because in his view section 12(f) "compels those students seeking financial aid who have not registered with the Selective Service in timely fashion to incriminate themselves and thereby violates the Fifth Amendment." For the rest, he deferred to Justice Marshall. Thelatter, in a much longer and more forceful opinion, took an approach not unlike the one he had used in a very different case, Beal v. Doe (1977).In both cases, he held that the withholding of government benefits from a financially needy individual--abortions for young women in Beal, collegemoney for young men in Selective Service--did indeed constitute a formof coercion or compulsion. Likewise in both dissenting opinions, he attackeda policy of what he judged as special punishment for the poor.
Section 12(f), Justice Marshall wrote, was unconstitutional not only on the Fifth Amendment question, but also from a standpoint not previously discussedin the case: that of the Fourteenth Amendment's Due Process Clause. When Congress enacted 12(f), it was well aware that some 674,000 of the 9,039,000 young men eligible for the draft had failed to register. In using the statute inquestion, however, it had sought to unfairly coerce the poor to shoulder theburden of national defense. Given his other disagreement with the statute, Justice Marshall wrote, it was not necessary to approach it on the bill of attainder issue; the Fifth Amendment critique was powerful enough. Marshall conceded that 12(f) did not force the student to incriminate himself before his educational institution, but "our inquiry cannot stop here." The statute in Marshall's eyes clearly coerced registration with the Selective Service System,and this led to reporting of self-incriminatory information to the federal government.
Hence a student who registered after the 30 day deadline "provides the Government with two crucial links in the chain of evidence necessary to prosecute him criminally." First of all, his birth date and date of registration offeredtwo pieces of evidence that the student has violated a law; second, and in Marshall's view even more important, the student thus called attention to histechnical violation of the Military Selective Service Act. "Armed with thesedata," Marshall wrote, "the Government need only prove that the student `knowingly' failed to register at the time prescribed by law in order to obtain aconviction."
As for the Fourteenth Amendment issue, Justice Marshall addressed the fact that it had not been raised by the rest of the Court when he noted "The majority's superficial, indeed cavalier, rejection of appellees' equal protection argument." This, he said, quoting himself in Flagg Bros., Inc. v. Brooks(1978), showed a "callous indifference to the realities of life for the poor." It was incorrect to say, as the majority had, that 12(f) treated all youngmen alike. The fact was, according to Marshall--who quoted a statement by Rep. Moffett during floor debate on the issue in 1982--"Only low- income and middle-income students will be caught in this trap."
Impact
Several authors writing in law journals soon after Selective Service responded with alarm. Hence Anthony L. Cogswell concluded a 1985 article in the Thurgood Marshall Law Review with the statement "It is possible thatSelective Service System may have a chilling effect on claims broughtunder the Fifth Amendment." Cheryl V. Cunningham, writing in the Loyola Law Review, sounded a more muted tone: noting that the case "marks a retreat from the course paved in the 1960s by a Court then more prone to expand the privilege against self-incrimination," she went on to say that "Most probably, Minnesota Public Interest Research Group will not arouse the concern it deserves." By and large, this statement has proven true, as very few Supreme Court cases in subsequent years have drawn on the Court's judgment in this one. The end of the Cold War in the period from 1989 to 1992 helped to reduce concern about the draft, though subsequent U.S. police actions in Iraq,Bosnia, Haiti, and other locales have served to raise it again.
Related Cases
Financial Aid Conditions
The conditions that a student must meet to receive financial aid can vary from state to state and from school to school. On the federal level, the UnitedStates Department of Education sets various conditions for both schools and students to qualify for federal funds. Registration for selective service by all adult males over the age of eighteen is mandatory for male students to receive financial aid.
The forms of financial aid are many and varied, ranging from loans and grantsto scholarships and work-study arrangements. Typically, schools determine what kind of financial aid a student qualifies for based on need. If a studenthas more than a certain amount of income and assets, that student may not qualify for need-based grants or scholarships or loans. The most important factor after receiving financial aid is academic performance and progress. If a student is not making satisfactory progress toward a degree, or if the studentis not maintaining enough class credits, then the student may lose financialaid.
Sources
University of Minnesota Office of Financial Aid. 1998.
Selective Service System of the United States
Appellee
Minnesota Public Interest Research Group, et al.
Appellant's Claim
That section 12(f) of the Military Selective Service Act did not constitute abill of attainder or a violation of the Fifth Amendment protection against compelled self-incrimination.
Chief Lawyer for Appellant
Rex E. Lee, U.S. Solicitor General
Chief Lawyer for Appellee
William J. Keppel
Justices for the Court
Warren E. Burger (writing for the Court), Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist, John Paul Stevens, Byron R. White
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall (Harry A. Blackmun did not participate)
Place
Washington, D.C.
Date of Decision
5 July 1984
Decision
That section 12(f) of the Military Selective Service Act, which denied federal financial assistance to male students between the ages of 18 and 26 who hadnot registered for the draft, constituted neither a bill of attainder nor aviolation of appellees' Fifth Amendment privilege against compelled self-incrimination.
Significance
Selective Service v. Minnesota Public Interest Research Group raised issues which date back as far as the post-Civil War era of Reconstruction, when the 1867 cases Cummings v. Missouri and Ex parte Garland addressed concerns over the Bill of Attainder Clause of the Constitution. A billof attainder, as the Court had defined it in Nixon v. Administrator of General Services (1977), was "a law that legislatively determines guilt andinflicts punishment upon an identifiable individual without provision of theprotections of a judicial trial," thus unfairly subjecting an individual to judgment without the benefit of a genuine legal action. The case also established important distinctions regarding prohibitions against self-incriminationembodied in the Fifth Amendment.
Uncle Sam and Eligible Young Men
Under section 3 of the Military Selective Service Act, the president of the United States is empowered to require every male citizen and resident alien inthe country between the ages of 18 and 26 to register for military service under the draft. On 2 July 1980, President Jimmy Carter signed Presidential Proclamation No. 4771, which required all young men to register within 30 daysof their eighteenth birthday.
On 8 September 1982, Congress passed the Department of Defense AuthorizationAct of 1983, thereby adding section 12(f) to the Selective Service Act. Under12(f), eligible young male students who failed to register would be ineligible for federal financial assistance under Title IV of the Higher Education Act of 1965. Under section 12(f)(2), applicants for such assistance were required to file a statement with their college, university, or trade school showing that they had complied with the draft registration law. Clauses (3) and (4)of 12(f) further required the secretary of education, working with the director of Selective Service, to prescribe methods for verifying statements of compliance, and to issue regulations for implementation. In their final form, as issued on 11 April 1983, these regulations stipulated that no applicant could receive financial aid for higher education under Title IV unless he firstfiled a statement certifying that he had registered with the Selective Service or that, due to a specified reason such as a physical impairment which would prevent him from military service, he was exempt from the registration requirement. The provision did not require the applicant to state the date on which he had registered.
In November of 1982, an organization called the Minnesota Public Interest Research Group (MPIRG) filed a complaint with the U.S. District Court in Minnesota to enjoin, or stop, the federal government's operation of 12(f). The district court dismissed MPIRG for lack of standing, but did allow three anonymousstudents to stand in as plaintiffs in the case. The students, still operating under the MPIRG name and in conjunction with MPIRG counsel, held that theyresided in Minnesota; that they required financial aid to complete their education; that they intended to apply for such aid; and that though they were eligible for the draft, they had failed to register with the Selective Service.Later they consolidated their suit with that of three other anonymous youngmen making essentially the same claim.
In March of 1983, the district court granted a preliminary injunction restraining the Selective Service from enforcing section 12(f). The court's reasoning was twofold. First, it held that 12(f) was a bill of attainder, and thus "clearly singles out an ascertainable group based on past conduct" and "legislatively determines the guilt of this ascertainable group." Second, the court held that 12(f) violated the appellees' privilege against compelled self-incrimination as guaranteed under the Fifth Amendment, because it compelled students requesting financial aid to confess the crime of not having registered forthe draft.
On 16 June 1983, the district court issued a nationwide injunction against the enforcement of 12(f), but less than two weeks later, on 29 June, the U.S. Supreme Court stayed that order pending docketing and final disposition of theappeal. Filing amici curiae briefs urging affirmance of the lower court's ruling were individuals representing Swarthmore College and the University of Minnesota. The trustees of Boston University filed a brief urging reversal.
Questions of Punitive Intent and Compulsion
By a vote of 6-2 the Court reversed the ruling of the lower court. Chief Justice Burger, writing for the Court, addressed the two issues under debate: thebill of attainder question and the Fifth Amendment question. On both counts,he found 12(f) fully constitutional, an opinion in which Justices O'Connor,Rehnquist, Stevens, and White joined, and with which Powell concurred in partwhile concurring in the judgment. Justices Brennan and Marshall dissented, and though both filed opinions, the latter's was much longer and more forceful.
A bill of attainder, the Chief Justice held, quoting Nixon v. Administrator of General Services, was "a law that legislatively determines guilt andinflicts punishment upon an identifiable individual without provision of theprotections of a judicial trial." An example of a bill of attainder was a provision in the post-Civil War Constitution of Missouri, which prevented a person from entering a given profession unless he swore under oath that he had not "been a member of, or connected with, any order, society, or organizationinimical to the government of the United States." The law, which was clearlyintended to bar former supporters of the Confederate government from any rolein public life, was struck down in Cummings v. Missouri (1867), and the Court struck down a similar law in Ex parte Garland (1867).
Section 12(f), on the other hand, did not single out those who failed to register, or make them ineligible based on that past conduct. It did not requireregistration within the time period established by the Presidential Proclamation, nor did it deem late registrants ineligible for aid. Rather, it "clearlygives non-registrants 30 days after receiving notice that they are ineligible for Title IV aid to register for the draft and qualify for aid." Nor did itinflict punishment, at least as that term was understood in the Bill of Attainder Clause in the Constitution. "It does not even deprive appellees of Title IV benefits permanently," the Chief Justice wrote, "since it leaves open perpetually the possibility of qualifying for aid." In passing 12(f), Congresshad meant simply to "encourage registration" by those who were required to register and had not done so. It was not punitive in nature, but rather was intended to provide "a rational means to improve compliance with the registration requirements."
With regard to the Fifth Amendment privilege against compelled self-incrimination, Burger held that since a student who had not registered with the Selective Service would be bound to know that his application for financial aid would be denied, he was by no means under any "compulsion" to seek that aid. Inother words, applying for aid was a choice he would have to make of his own free will, and if he did not want to sign up for the draft, then he would haveto accept the consequences of that freely taken action--including the withholding of federal funds. As for the fact that a student who changed his mind and registered for the draft after all might be registering after the 30 day deadline, this too failed to constitute compulsory self-incrimination. The lawdid not require a student to inform officials at his school whether or not he had registered late, nor would lateness in registering disqualify a studentfrom applying for financial aid. Because the appellees had not attempted toregister, they "had no occasion to assert their Fifth Amendment privilege when asked to state their dates of birth . . . " Nor, finally, had the government threatened them with any consequences--short of not receiving a financial aid check--for their failure to comply. "Under these circumstances," Burger wrote, "appellees will not be heard to complain that 12(f) violates their FifthAmendment rights by forcing them to acknowledge during the draft process they have avoided that they are registering late."
Justice Powell concurred in part and concurred in the judgment. In his view,the bill of attainder issue could be settled much more easily than the Courthad disposed of it, simply by noting that 12(f) was not punitive legislation,a distinction established in Nixon v. Administrator of General Services. The Selective Service Act--and only that act--provided a punishment for the crime of failing to register for the draft. Section 12(f), by contrast, "authorizes no punishment in any normal or general acceptance of that familiarterm." Using much the same logic as the Court, but applying it more directly,Powell was saying that withholding a privilege is not the same thing as conferring a punishment. Far from authorizing punitive actions, section 12(f) "provides a benefit at the expense of taxpayers generally for those who requestand qualify for it." No one was compelled to receive it, nor was any minoritygroup forbidden from receiving it. Since he found that 12(f) was not punitive in purpose or effect, Powell held that it was unnecessary to address the other questions the Court had reviewed in examining the bill of attainder issue.
Marshall's Dissent: "A De Facto Classification Based on Wealth"
Justice Brennan issued a short dissenting opinion, wherein he stated that hewould affirm the lower court's judgment because in his view section 12(f) "compels those students seeking financial aid who have not registered with the Selective Service in timely fashion to incriminate themselves and thereby violates the Fifth Amendment." For the rest, he deferred to Justice Marshall. Thelatter, in a much longer and more forceful opinion, took an approach not unlike the one he had used in a very different case, Beal v. Doe (1977).In both cases, he held that the withholding of government benefits from a financially needy individual--abortions for young women in Beal, collegemoney for young men in Selective Service--did indeed constitute a formof coercion or compulsion. Likewise in both dissenting opinions, he attackeda policy of what he judged as special punishment for the poor.
Section 12(f), Justice Marshall wrote, was unconstitutional not only on the Fifth Amendment question, but also from a standpoint not previously discussedin the case: that of the Fourteenth Amendment's Due Process Clause. When Congress enacted 12(f), it was well aware that some 674,000 of the 9,039,000 young men eligible for the draft had failed to register. In using the statute inquestion, however, it had sought to unfairly coerce the poor to shoulder theburden of national defense. Given his other disagreement with the statute, Justice Marshall wrote, it was not necessary to approach it on the bill of attainder issue; the Fifth Amendment critique was powerful enough. Marshall conceded that 12(f) did not force the student to incriminate himself before his educational institution, but "our inquiry cannot stop here." The statute in Marshall's eyes clearly coerced registration with the Selective Service System,and this led to reporting of self-incriminatory information to the federal government.
Hence a student who registered after the 30 day deadline "provides the Government with two crucial links in the chain of evidence necessary to prosecute him criminally." First of all, his birth date and date of registration offeredtwo pieces of evidence that the student has violated a law; second, and in Marshall's view even more important, the student thus called attention to histechnical violation of the Military Selective Service Act. "Armed with thesedata," Marshall wrote, "the Government need only prove that the student `knowingly' failed to register at the time prescribed by law in order to obtain aconviction."
As for the Fourteenth Amendment issue, Justice Marshall addressed the fact that it had not been raised by the rest of the Court when he noted "The majority's superficial, indeed cavalier, rejection of appellees' equal protection argument." This, he said, quoting himself in Flagg Bros., Inc. v. Brooks(1978), showed a "callous indifference to the realities of life for the poor." It was incorrect to say, as the majority had, that 12(f) treated all youngmen alike. The fact was, according to Marshall--who quoted a statement by Rep. Moffett during floor debate on the issue in 1982--"Only low- income and middle-income students will be caught in this trap."
Impact
Several authors writing in law journals soon after Selective Service responded with alarm. Hence Anthony L. Cogswell concluded a 1985 article in the Thurgood Marshall Law Review with the statement "It is possible thatSelective Service System may have a chilling effect on claims broughtunder the Fifth Amendment." Cheryl V. Cunningham, writing in the Loyola Law Review, sounded a more muted tone: noting that the case "marks a retreat from the course paved in the 1960s by a Court then more prone to expand the privilege against self-incrimination," she went on to say that "Most probably, Minnesota Public Interest Research Group will not arouse the concern it deserves." By and large, this statement has proven true, as very few Supreme Court cases in subsequent years have drawn on the Court's judgment in this one. The end of the Cold War in the period from 1989 to 1992 helped to reduce concern about the draft, though subsequent U.S. police actions in Iraq,Bosnia, Haiti, and other locales have served to raise it again.
Related Cases
- Cummings v. Missouri, 4 Wall. 277 (1867).
- Ex parte Garland, 71 U.S. 333 (1867).
- Garrity v. New Jersey, 385 U.S. 493 (1967).
- Marchetti v. United States, 390 U.S. 39 (1968).
- Lefkowitz v. Turley, 414 U.S. 70 (1973).
- Nixon v. Administrator of General Services, 433 U.S. 425 (1977).
Financial Aid Conditions
The conditions that a student must meet to receive financial aid can vary from state to state and from school to school. On the federal level, the UnitedStates Department of Education sets various conditions for both schools and students to qualify for federal funds. Registration for selective service by all adult males over the age of eighteen is mandatory for male students to receive financial aid.
The forms of financial aid are many and varied, ranging from loans and grantsto scholarships and work-study arrangements. Typically, schools determine what kind of financial aid a student qualifies for based on need. If a studenthas more than a certain amount of income and assets, that student may not qualify for need-based grants or scholarships or loans. The most important factor after receiving financial aid is academic performance and progress. If a student is not making satisfactory progress toward a degree, or if the studentis not maintaining enough class credits, then the student may lose financialaid.
Sources
University of Minnesota Office of Financial Aid. 1998.
User Comments Add a comment…
8 months ago
I just found out on my birthday no less that im not elegable for financial aid because i didnt fill out a card i knew little about. I just left my business and my wife because she cheated. Im trying to start over and now i cant, i have little money and im 29 today i cant afford to pay loans till im 40. I need help but i dont know what to do.