Rhea v. District Board of Trustees, 109 So. 3d 851

Rhea sued the College of Santa Fe College for mandamus relief (Count One) and a declaratory judgment (Count Two) in a second amended complaint.
Count One alleged the e-mail requesting unredacted disclosure was a public record and the College violated the Public Records Act by withholding the name under FERPA.
Count Two alleged the College violated its own Rule 7.36 governing student complaints and sought declaratory relief, damages, and costs.
The trial court dismissed both counts with prejudice, finding FERPA barred disclosure of the unredacted e-mail and that no justiciable issue existed for declaratory relief.
Rhea appealed, challenging the dismissal as to both counts.
The appellate court affirmed, holding the unredacted e-mail is a public record but exempt under FERPA, and that no present justiciable need for a declaration existed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether FERPA exempts disclosure of the unredacted e-mail	Rhea argued the e-mail is not an education record and FERPA does not protect the name.	The College argued FERPA protections apply to education records and the unredacted e-mail contains student identifiers.	Count One affirmed; disclosure is barred by FERPA as an education record.
Whether Rhea is entitled to declaratory relief under Rule 7.36	Rhea seeks declarations about rights under Rule 7.36 due to alleged violations affecting rehiring.	The College contends the e-mail was not a formal complaint and no live controversy exists for declaratory relief.	Count Two affirmed; no present justiciable controversy or right demonstrated.

Shevin v. Byron, Harless, Schaffer, Reid & Assocs., Inc., 379 So.2d 633 (Fla. 1980) (public records mandamus requires a clear legal right and duty)
Meyers v. City of Jacksonville, 754 So.2d 198 (Fla. 1st DCA 2000) (dismissal for failure to state a claim; de novo standard of review)
Connolly v. Sebeco, Inc., 89 So.2d 482 (Fla.1956) (pleading standards and deference to complaint in dismissal context)
Weaver v. Leon Cnty. Classroom Teachers Ass’n, 680 So.2d 478 (Fla. 1st DCA 1996) (limits on judicial consideration of pleadings)
State v. City of Clearwater, 863 So.2d 149 (Fla. 2003) (public records definition and access standard)
National Collegiate Athletic Ass’n v. Associated Press, 18 So.3d 1201 (Fla. 1st DCA 2009) (public records not limited to paper; applies to digital records)
Plymel v. Moore, 770 So.2d 242 (Fla. 1st DCA 2000) (mandamus and ministerial duties)
Hatten v. State, 561 So.2d 562 (Fla. 1990) (mandamus elements and procedural posture)
Town of Manalapan v. Rechler, 674 So.2d 789 (Fla. 4th DCA 1996) (mandamus and ministerial duties; standards for relief)