For example, does it extend beyond registration to areas such as grades or scholarships. One court criticized a free-standing property right because it was concerned that students would not be entitled to a hearing if they received a result they did not like. While this may seem like an absurd result, an Eight Circuit panel actually suggested that a student can have a proprietary interest in grading to the extent that he or she cannot be graded capriciously. We can expand it further. For example, could a student have a real estate interest in a school-funded scholarship or a football team? Increasing property interests also increases costs because states must pay to provide more procedures for individuals, which is another reason Roth sought to leave the power to determine rights in the hands of the state. State. Courts should not resort to the stand-alone approach as it undermines the Supreme Court.