Gonzaga University v. Doe
Encyclopedia
Gonzaga University v. Doe, 536 U.S. 273
(2002), was a case in which the Supreme Court of the United States
ruled that the Family Educational Rights and Privacy Act of 1974, which prohibits the federal government from funding educational institutions that release education records to unauthorized persons, does not create a right which is enforceable under 42 U.S.C. § 1983
.
A Gonzaga University
undergraduate student sued the school and the teacher, League, under 42 U.S.C. § 1983, alleging a violation of the Family Educational Rights and Privacy Act of 1974. The student was planning to become an elementary teacher upon graduation, and under Washington State Law, all new teachers required an affidavit
of good moral character from their graduating college. The teacher in charge of certifying such affidavits, League, overheard a student conversation discussing sexual misconduct by the undergraduate student. Subsequently, League launched an investigation into the matter, and refused to certify the student's necessary affidavit of good moral character. The student sued claiming a violation of his confidentiality rights.
The Supreme Court
held that Family Educational Rights and Privacy Act's nondisclosure provisions created no personal rights to enforce under 42 U.S.C. § 1983. The Family Educational Rights and Privacy Act prohibits "the federal funding of educational institutions that have a policy or practice of releasing education records to unauthorized persons." 536 U.S. at 276. The court reasoned that this does not grant any personal rights to enforce under the civil rights provisions of § 1983, since the statute
only addresses federal funding.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2002), was a case in which the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
ruled that the Family Educational Rights and Privacy Act of 1974, which prohibits the federal government from funding educational institutions that release education records to unauthorized persons, does not create a right which is enforceable under 42 U.S.C. § 1983
Civil Rights Act of 1871
The Civil Rights Act of 1871, , enacted April 20, 1871, is a federal law in force in the United States. The Act was originally enacted a few years after the American Civil War, along with the 1870 Force Act. One of the chief reasons for its passage was to protect southern blacks from the Ku Klux...
.
A Gonzaga University
Gonzaga University
Gonzaga University is a private Roman Catholic university located in Spokane, Washington, United States. Founded in 1887 by the Society of Jesus, it is one of 28 member institutions of the Association of Jesuit Colleges and Universities and is named after the young Jesuit saint, Aloysius Gonzaga...
undergraduate student sued the school and the teacher, League, under 42 U.S.C. § 1983, alleging a violation of the Family Educational Rights and Privacy Act of 1974. The student was planning to become an elementary teacher upon graduation, and under Washington State Law, all new teachers required an affidavit
Affidavit
An affidavit is a written sworn statement of fact voluntarily made by an affiant or deponent under an oath or affirmation administered by a person authorized to do so by law. Such statement is witnessed as to the authenticity of the affiant's signature by a taker of oaths, such as a notary public...
of good moral character from their graduating college. The teacher in charge of certifying such affidavits, League, overheard a student conversation discussing sexual misconduct by the undergraduate student. Subsequently, League launched an investigation into the matter, and refused to certify the student's necessary affidavit of good moral character. The student sued claiming a violation of his confidentiality rights.
The Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
held that Family Educational Rights and Privacy Act's nondisclosure provisions created no personal rights to enforce under 42 U.S.C. § 1983. The Family Educational Rights and Privacy Act prohibits "the federal funding of educational institutions that have a policy or practice of releasing education records to unauthorized persons." 536 U.S. at 276. The court reasoned that this does not grant any personal rights to enforce under the civil rights provisions of § 1983, since the statute
Statute
A statute is a formal written enactment of a legislative authority that governs a state, city, or county. Typically, statutes command or prohibit something, or declare policy. The word is often used to distinguish law made by legislative bodies from case law, decided by courts, and regulations...
only addresses federal funding.