Gonzaga Univ. v. Doe, 536 U.S. 273, 5 (2002)

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Cite as: 536 U. S. 273 (2002)

Opinion of the Court

Respondent John Doe is a former undergraduate in the School of Education at Gonzaga University, a private university in Spokane, Washington. He planned to graduate and teach at a Washington public elementary school. Washington at the time required all of its new teachers to obtain an affidavit of good moral character from a dean of their graduating college or university. In October 1993, Roberta League, Gonzaga's "teacher certification specialist," overheard one student tell another that respondent engaged in acts of sexual misconduct against Jane Doe, a female undergraduate. League launched an investigation and contacted the state agency responsible for teacher certification, identifying respondent by name and discussing the allegations against him. Respondent did not learn of the investigation, or that information about him had been disclosed, until March 1994, when he was told by League and others that he would not receive the affidavit required for certification as a Washington schoolteacher.

Respondent then sued Gonzaga and League (petitioners) in state court. He alleged violations of Washington tort and contract law, as well as a pendent violation of 1983 for the release of personal information to an "unauthorized person" in violation of FERPA.1 A jury found for respondent on all counts, awarding him $1,155,000, including $150,000 in compensatory damages and $300,000 in punitive damages on the FERPA claim.

1 The Washington Court of Appeals and the Washington Supreme Court found petitioners to have acted "under color of state law" for purposes of 1983 when they disclosed respondent's personal information to state officials in connection with state-law teacher certification requirements. 143 Wash. 2d 687, 710-711, 24 P. 3d 390, 401-402 (2001). Although the petition for certiorari challenged this holding, we agreed to review only the question posed in the first paragraph of this opinion, a question reserved in Owasso Independent School Dist. No. I-011 v. Falvo, 534 U. S. 426, 430- 431 (2002). We therefore assume without deciding that the relevant disclosures occurred under color of state law.


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