Chicago Tribune Co. v. Board of Trustees of the University of Illinois
680 F.3d 1001
7th Cir.2012Background
- Tribune published a series exposing Illinois University admissions via clout.
- Tribune sought Illinois FOIA records, including parents’ identities and those involved in applications.
- University invoked Exemption 1(a) and FERPA 20 U.S.C. §1232g(b)(1), arguing federal law restricts disclosure.
- District court granted Tribune summary judgment, interpreting §1232g(b)(1) as governing only direct federal-law prohibitions.
- Seventh Circuit held Grable jurisdiction not applicable; case arises primarily under state law and should be brought in state court; district court’s judgment vacated and remanded for dismissal for lack of subject-matter jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal-question jurisdiction exists | Tribune seeks federal-law interpretation of FERPA conditions | University raises federal-defense under §1232g | No federal-question jurisdiction; state-law claim; remanded |
| Whether Grable-style jurisdiction applies | Grable supports federal resolution of a substantial federal issue | Grable inapplicable where no federal-law dispute is actually presented | Grable does not apply; jurisdiction not proper in federal court |
| Meaning of 'specifically prohibited from disclosure by federal law' | Federal-law condition governs disclosure | State contract/Grant conditions may govern; not a pure federal-law prohibition | Not a federal-law prohibition; state-law issues predominate; no federal jurisdiction |
| Whether Tribune is proper plaintiff for federal declaratory relief | Tribune seeks ruling on federal-law interpretation to vindicate its FOIA rights | University would rely on federal defenses but Tribune is not proper plaintiff for federal decree | Tribune not proper plaintiff for declaratory relief; forum should be state court |
Key Cases Cited
- Grable & Sons Metal Prods., Inc. v. Darue Eng’g & Mfg., 545 U.S. 308 (U.S. 2005) (federal-question jurisdiction requires a substantial federal issue central to the claim)
- Empire HealthChoice Assur., Inc. v. McVeigh, 547 U.S. 677 (U.S. 2006) (Grable not to be understood as broad endorsement of federal-forum resolution of disputes)
- Gonzaga Univ. v. Doe, 536 U.S. 273 (U.S. 2002) (no private federal right of action to enforce federal funding conditions)
- Skelly Oil Co. v. Phillips Petroleum Co., 339 U.S. 667 (U.S. 1950) (private plaintiff cannot litigate anticipated federal defenses in federal court under declaratory judgment)
- Franchise Tax Bd. v. Construction Laborers Vacation Trust, 463 U.S. 1 (U.S. 1983) (federal jurisdiction not available where no federal-question or complete preemption)
- Owasso Indep. School Dist. v. Falvo, 534 U.S. 426 (U.S. 2002) (payment conditions may create contract-based limits on disclosure)
- United States v. Miami Univ., 294 F.3d 797 (6th Cir. 2002) (enforcement of federal grant conditions may occur in state or federal court)