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Enforcement ActionLow RiskMultistate

States Sue Education Dept Over Student Data Survey Mandate

U.S. Department of EducationMarch 11, 2026New York Attorney General

Summary

New York Attorney General Letitia James, joined by 16 other states, sued the U.S. Department of Education over a new survey requiring colleges to submit extensive student data, arguing it violates the Administrative Procedure Act and threatens student privacy. The lawsuit seeks to block the mandate and prevent penalties for non-compliance.

Remedy

The attorneys general are requesting a court order to prohibit the Department of Education from enforcing the new data collection survey and from penalizing institutions that refuse to comply.

Injunction

Contract Impact

In-house legal teams should review all agreements with educational institutions, particularly vendor contracts, data processing agreements, and any contracts involving federal compliance reporting. Focus on clauses governing data collection scope, privacy compliance (especially FERPA), indemnification for regulatory changes, and termination rights for non-compliance with new mandates. Specific changes may include adding explicit opt-out mechanisms for contested surveys, renegotiating data retention terms to align with new privacy threats, and inserting clauses that require mutual agreement on material compliance changes to avoid unilateral penalties.

Contract Search Terms

student data collection clauseFERPA compliance provisiondata sharing agreementsurvey mandate clauseadministrative procedure act complianceprivacy impact assessment requirementdata retention scheduleindemnification for regulatory changestermination for non-complianceconsent for data submission

Laws Cited

Administrative Procedure Act

Violation Types

Entity Details

Entity

U.S. Department of Education

Industry

Education

Multistate Coalition

Official Sources

Related Enforcement Actions

CA

U.S. Department of Education

California Attorney General Rob Bonta filed a lawsuit against the U.S. Department of Education to block the expansion of IPEDS data collection requiring colleges to submit race-linked student data. The lawsuit argues the demand is arbitrary, capricious, and burdensome, and could enable costly partisan investigations. A multistate coalition co-led the challenge.

IL

U.S. Department of Education

Illinois Attorney General Kwame Raoul, joined by 16 other attorneys general, filed a lawsuit against the U.S. Department of Education to stop new data collection requirements under IPEDS that threaten student privacy by requesting sensitive personal information including income, test scores, and GPA.

MA

U.S. Department of Education

Massachusetts Attorney General Andrea Campbell co-led a coalition of 17 attorneys general in filing a lawsuit against the Trump Administration to stop new data reporting requirements for colleges and universities through IPEDS. The requirements demand detailed student data disaggregated by race and sex, retroactive for seven years, which the coalition argues jeopardizes student privacy and could lead to baseless investigations.

CT

U.S. Department of Education

Connecticut Attorney General William Tong joined a coalition of 17 attorneys general in filing a lawsuit against the U.S. Department of Education to stop new data reporting requirements under IPEDS that demand detailed student information. The coalition argues the requirements are unlawful, arbitrary, and jeopardize student privacy by requesting in-depth data that could lead to inadvertent errors and baseless investigations. The lawsuit seeks an injunction to block the implementation of these requirements.

WA

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Attorney General Nick Brown of Washington led a coalition of 17 state attorneys general in filing a lawsuit against the U.S. Department of Education on March 11, 2026, challenging new requirements for the IPEDS survey that demand race- and sex-disaggregated student data retroactive seven years. The coalition alleges the rushed rule violates the law, jeopardizes student privacy by collecting in-depth student information, and imposes undue burdens on institutions with unclear data definitions and risk of severe penalties for errors. The lawsuit seeks to invalidate the rule, arguing it was arbitrarily implemented without proper procedure and poses widespread privacy risks to students.

CT

U.S. Department of Education

Connecticut Attorney General William Tong joined 18 other attorneys general in filing a comment letter opposing a U.S. Department of Education proposal to expand data collection on race, admissions, and student performance from colleges and universities. The coalition argues the proposal is unreasonably burdensome, unlikely to yield quality data, and could be misused to target lawful diversity, equity, and inclusion initiatives, raising student privacy concerns.