Gonzaga University v. Doe
United States Supreme Court
536 U.S. 273 (2002)
John Doe (plaintiff) was a student at Gonzaga University (Gonzaga) (defendant). To become a teacher, Doe needed a letter of good standing from the dean of his college. Gonzaga’s teacher-certification specialist would not allow the dean to provide the letter of good standing because Doe was suspected of sexual misconduct with a female student. The teacher specialist informed the state agency responsible for teacher certification about Doe and the suspected sexual misconduct. Doe sued Gonzaga in state court under 42 U.S.C. § 1983 for a violation of the Family Educational Rights and Privacy Act of 1974 (FERPA). FERPA prohibited the federal funding of schools that had a policy or practice of revealing a student’s educational records. If a violation of FERPA occurred, FERPA instructed the Secretary of Education to pull the school’s funding. A jury awarded Doe damages for Gonzaga’s FERPA violation. The Washington Court of Appeals reversed and held that § 1983 cannot be used to enforce a claim of a violation of a federal law that does not create a private cause of action. The Washington Supreme Court reversed and reinstated the damages. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Rehnquist, C.J.)
Concurrence (Breyer, J.)
Dissent (Stevens, J.)
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