Gonzaga University v. Doe

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Gonzaga University v. Doe

Argued April 24, 2002
Decided June 20, 2002

Full case name:	Gonzaga University and Roberta S. League, Petitioners v. John Doe
Docket #:	01-679

Citations:	536 U.S. 273; 122 S. Ct. 2268; 153 L. Ed. 2d 309; 2002 U.S. LEXIS 4649; 70 U.S.L.W. 4577; 2002 Cal. Daily Op. Service 5458; 2002 Daily Journal DAR 6859; 15 Fla. L. Weekly Fed. S 436

Prior history:	On writ of certiorari to the Supreme Court of Washington. Doe v. Gonzaga Univ., 143 Wn.2d 687, 24 P.3d 390, 2001 Wash. LEXIS 381 (2001)

Holding

The Family Educational Rights and Privacy Act's nondisclosure provisions created no personal rights to enforce under 42 U.S.C. § 1983.

Court membership

Chief Justice: William Rehnquist
Associate Justices: John Paul Stevens, Sandra Day O'Connor, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer

Case opinions

Majority by: Rehnquist
Joined by: O'Connor, Scalia, Kennedy, Thomas
Concurrence by: Breyer
Joined by: Souter
Dissent by: Stevens
Joined by: Ginsburg

Laws applied

Family Educational Rights and Privacy Act of 1974, 42 U.S.C. § 1983

Gonzaga University v. Doe, 536 U.S. 273 (2002)^[1], 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.