In the 2001 case Gonzaga University and Roberta S. League v. John Doe, a student sued Gonzaga University for violating his privacy rights under the Family Educational Rights and Privacy Act (FERPA). The student claimed that university officials had improperly disclosed allegations of sexual misconduct against him to state teacher certification authorities without his consent. However, the U.S Supreme Court ruled in favor of Gonzaga University, stating that FERPA does not grant individuals enforceable rights under Section 1983 - a statute allowing individuals to sue for constitutional violations committed by those acting on behalf of governmental bodies or public entities receiving federal funds. The court reasoned that FERPA's provisions create no personal rights to sue because they are directed towards institutions rather than individuals; thus it is up to Congress or Department of Education sanctions rather than private lawsuits to ensure compliance with FERPA.

In the dissenting opinion for Gonzaga University and Roberta S. League v. John Doe, Justice Stevens argued that the majority's decision to deny individuals a private right of action under FERPA was inconsistent with previous rulings where similar rights were recognized under other federal statutes. He contended that Congress intended to create such individual rights when it enacted FERPA, as evidenced by its use of explicit "rights-creating" language in the statute. Furthermore, he pointed out that denying individuals this right would undermine their ability to enforce their privacy interests against unlawful disclosures of personal information by educational institutions. In his view, allowing lawsuits against violators is an essential tool for deterring violations and ensuring compliance with federal law.