Gonzaga University. in Washington Law Schools
Gonzaga University v. Doe, 536 U.S. 273 (2002)
1. Background & Facts
A student (referred to as "Doe") at Gonzaga University alleged that the university violated his privacy rights by disclosing his educational records without his consent.
The claim was based on the Family Educational Rights and Privacy Act (FERPA), a federal law protecting the privacy of student education records.
Doe tried to sue Gonzaga University, asserting that the university had breached FERPA by sharing confidential information improperly.
2. Legal Issue
Does FERPA create a private right of action that allows students to sue educational institutions for alleged violations?
In other words, can a student sue a university under FERPA if their educational records are disclosed unlawfully?
3. FERPA in Brief
FERPA prohibits educational institutions receiving federal funds from disclosing students’ education records without consent.
It includes administrative and procedural safeguards but does not explicitly mention a private right of action (a direct lawsuit by individuals).
4. Supreme Court’s Reasoning
The Supreme Court examined whether Congress intended to create a private cause of action under FERPA.
The Court applied the Cort v. Ash (1975) test, which asks:
Whether the plaintiff is part of the class the statute intends to protect,
Whether there is an indication of legislative intent to create or deny such a remedy,
Whether the cause of action is consistent with the underlying purposes of the statute,
Whether it is traditionally a matter for state law.
The Court found:
FERPA’s language and structure show no clear intention to create a private right of action.
The enforcement mechanism under FERPA is administrative — the Department of Education can withhold federal funds from violating institutions.
Allowing private lawsuits would disrupt this administrative scheme.
Therefore, FERPA does not give students the right to sue educational institutions in federal court.
5. Judgment
The Supreme Court ruled in favor of Gonzaga University, holding that FERPA does not create a private right of action.
Students cannot bring civil suits for FERPA violations; enforcement is limited to federal administrative actions.
6. Significance of the Case
Clarified the limits of federal privacy protections in education.
Confirmed that statutory rights must clearly indicate if private lawsuits are allowed.
Established a precedent limiting the ability of individuals to sue under federal statutes that do not explicitly provide private remedies.
Shifted the responsibility of enforcement of FERPA violations to the federal government, rather than private parties.
7. Impact on Educational Institutions and Students
Educational institutions cannot be sued privately under FERPA, which reduces litigation risks for schools.
Students must rely on federal administrative enforcement or other legal avenues for privacy protection.
Reinforced the idea that private rights of action are not assumed but must be expressly or clearly implied by Congress.
8. Summary Table
| Aspect | Details |
|---|---|
| Case Name | Gonzaga University v. Doe |
| Citation | 536 U.S. 273 (2002) |
| Legal Issue | Whether FERPA creates a private right of action |
| Court’s Holding | No private right of action under FERPA |
| Key Reasoning | Congressional intent, statutory language, administrative scheme |
| Impact | Enforcement limited to federal agencies, no private lawsuits |
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