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39 J.C. & U.L. 567 (2013)
The Chicago Tribune v. the University of Illinois: The Latest Iteration of New Textualist Interpretation of FERPA by the Federal Courts

handle is hein.journals/jcolunly39 and id is 595 raw text is: THE CHICAGO TRIBUNE V THE UNIVERSITY OF ILLINOIS: THE LATEST ITERATION OF NEW TEXTUALIST INTERPRETATION OF FERPA BY THE FEDERAL COURTS SAM SCHMITT* DAVID ARONOFSKY** INTRODUCTION ...................................... ......568 I. FERPA TEXT AND STRUCTURE ..............................569 II. FERPA CASE LAW .......................................573 A. FERPA in the Supreme Court........... ...................573 B. FERPA According to Owasso and Gonzaga in the Federal Circuit Courts ....................................578 1. Tenth Circuit. ...................................579 2. Sixth Circuit .......................... ...............581 3. Seventh Circuit. ........................... ......582 4. Second Circuit ......................................585 5. Third Circuit ...................................587 6. Fifth Circuit ..........................................588 7. Ninth Circuit ...................................589 III. THE CHICAGO TRIBUNE V. THE UNIVERSITY OF ILLIATOIS....... .....590 * Sam Schmitt is a third-year law student matriculating at the University of Montana School of Law and visiting at George Mason University School of Law. Mr. Schmitt holds a master's degree in public administration from the New Mexico State University and an honors degree in history, also from the New Mexico State University. He can be reached at schmittysam@gmail.com. ** David Aronofsky recently retired as full-time General Counsel at the University of Montana to assume new academic program responsibilities. He has been and remains a University of Montana adjunct faculty member in the School of Law and College of Education. Dr. Aronofsky received his J.D. and B.S. in Education from the University of Texas at Austin; Ph.D. in Higher Education from Florida State University; and M.Ed. in Counseling from Southern Methodist University. He can be reached by mail at the University of Montana, 32 Campus Dr., University Hall 135, Missoula, MT 59812.The views expressed in this article are solely those of the authors personally and should not be attributed to the University of Montana, the School of Law, College of Education, or George Mason University School of Law. Special thanks to students Nathaniel Jacob, Brianne Radovich, and Benjamin Sudduth for their help editing, proofing, and footnoting this article. 567

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