Summary of Gonzaga v. DOE
Citation: 536 U.S. 273
Relevant Facts: A Gonzaga University student was planning to become a public elementary school teacher in Washington. One of the requirements for making that happen was to obtain an affidavit regarding good moral character from their alma mater. The student’s teacher certification specialist overheard damaging information about the student having been involved in sexual misconduct, and contacted the state agency tasked with teacher certifications in order to discuss the allegations, disclosing not only the allegation but the student’s name and information. Consequently, the student was later informed that he would not receive the needed certification affidavit required to permit him to teach in the state. The student sued Gonzaga University in state court, claiming that the school violated the Family Educational Rights and Privacy Act of 1974, which prohibits the federal funding of schools that have a policy or practice of releasing students’ education records without their parents’ written consent. A jury found in favor of the student and awarded him both compensatory and punitive damages. The State Supreme Court found, however, that FERPA did not lend itself to being litigated regarding a private action, but that the nondisclosure provision did create an enforceable right as applied to the federal funding issue. The matter was heard by the Supreme Court.
Issues: The legal question presented was whether a student can sue a private university for damages to enforce provisions of FERPA?
Holding: The Court held that no, a student could not.
Reasoning: The Court reasoned this case could not go forward because the relevant provision of FERPA dealt with federal funding rather than students’ disclosure vs. non-disclosure rights. The Court further reasoned that “FERPA’s nondisclosure provisions contain no rights-creating language, they have an aggregate, not individual, focus, and they serve primarily to direct the Secretary of Education’s distribution of public funds to educational institutions.” The language of the act was clear in not enforcing or proposing rights for students as that which the Gonzaga student needed to prevail on the merits.
Dissent: Justices Stevens and Ginsburg dissented, arguing that the Court’s opinion, “may be read as accepting the proposition that FERPA does indeed create both parental rights of access to student records and student rights of privacy in such records, but that those federal rights are of a lesser value because Congress did not intend them to be enforceable by their owners.”
Conclusion: This case was important because the Court overall concluded that federal educational spending legislation typically does not create enforceable rights for students unless explicitly stated.