Press-Citizen Co. v. University of Iowa

The Iowa Open Records Act required public institutions, such as the University of Iowa (the university) (defendant), to make their records publicly available upon request. A student at the university reported being sexually assaulted by two football players. Following significant publicity about the reported assault and the university’s handling of the report, the Iowa City Press-Citizen (Press-Citizen) (plaintiff), a newspaper, requested all of the university’s records relating to documents and communications among university officials about recently reported sexual assaults. The university located approximately 2,000 pages of documents responsive to the request but produced only 18 pages to the Press-Citizen. The university claimed that the other documents contained personal student information that the university could not disclose under the federal Family Educational Rights and Privacy Act (FERPA). The Press-Citizen sued the university to compel production of the documents under the Iowa Open Records Act. After reviewing the contested documents in camera, the district court ordered the university to produce some documents in full and to produce other documents with redactions. The university appealed the order to the Iowa Supreme Court. The university argued that, under FERPA, many of the redacted documents ordered by the district court should be withheld because the Press-Citizen and the public could use the visible information and the report’s publicity to figure out the identity of the students mentioned in those documents.