Court Rules
All enforcement actions
Enforcement ActionLow RiskMultistate

State AGs Sue Education Dept Over IPEDS Student Privacy Risks

Department of EducationMarch 11, 2026Oregon Attorney General

Summary

Privacy enforcement action where Oregon AG and a coalition of 16 other states sue the Trump Administration to stop the Department of Education's new IPEDS data reporting requirements, arguing they jeopardize student privacy, lack proper definitions, and risk data errors and identification.

Remedy

Seeking an injunction to block the Department of Education from implementing the new IPEDS data collection requirements and retroactive reporting demands.

Injunction

Contract Impact

In-house legal teams should review all agreements where the entity (e.g., colleges/universities) receives federal financial aid or handles student data, including federal aid compliance agreements, data processing addendums with the Department of Education, and vendor contracts involving student information. Specific clauses to scrutinize include data submission obligations, accuracy warranties, audit rights, indemnification for reporting errors, and privacy safeguards. Given the lawsuit's focus on rushed implementation, lack of definitions, and privacy risks, contracts may need amendments to: (1) define new data elements (e.g., race-neutral admissions criteria) clearly; (2) implement data validation and error-correction protocols; (3) restrict data use strictly to compliance with the stated IPEDS purpose; (4) address liability for inadvertent errors; and (5) ensure alignment with existing student privacy laws like FERPA, even if not explicitly cited.

Contract Search Terms

IPEDS compliance clausestudent data disclosure requirementsfederal survey mandatedata accuracy certificationprivacy safeguard for student recordsrace-neutral admissions reportingregulatory change notificationaudit rights for federal reportingdata error liabilitySupreme Court decision implementation

Violation Types

Entity Details

Entity

Department of Education

Industry

Other

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"Department of Education"
Violation Types
"jeopardize student privacy and could lead to individuals being easily identified"

Related Enforcement Actions

CT

Department of Education

Connecticut Attorney General William Tong, joined by 17 other attorneys general, filed a lawsuit against the U.S. Department of Education to block new IPEDS data reporting requirements that demand student information disaggregated by race and sex. The coalition argues the rushed implementation is unlawful, invades student privacy, and risks unreliable data and baseless investigations. They seek an injunction to halt the data collection and protect student privacy.

OR

U.S. Department of Transportation

Attorney General Dan Rayfield and a coalition of 21 attorneys general and Pennsylvania filed lawsuits against the U.S. Department of Transportation, FMCSA, and AAMVA to block demands for a database containing personal information of 17 million commercial drivers. The federal government threatened to withhold $10 million in funding unless the data was turned over, which the coalition argues violates privacy law.

OR

Office of the Comptroller of the Currency

Oregon Attorney General Dan Rayfield co-led a coalition of 10 states in a federal lawsuit against the Office of the Comptroller of the Currency (OCC) to block a rule that invalidates state laws requiring mortgage lenders to pay interest on escrow accounts. The lawsuit argues the OCC's rule oversteps federal authority, gives national banks a competitive advantage over state-chartered banks, and takes money away from homeowners.

OR

Nexstar Media Group

A federal judge ruled that Nexstar Media Group violated a court order requiring it to keep TEGNA Inc. operating as an independent company while a multistate antitrust lawsuit challenging the merger proceeds. The court found that Nexstar installed its own executives on TEGNA's board, failed to disclose the appointments, and lacked candor with the court. The court ordered Nexstar to comply immediately, file status reports, respond to discovery, and turn over board and financial documents, with a special master to oversee compliance.

OR

Administration for Children and Families (ACF)

Oregon Attorney General Dan Rayfield, joined by a coalition of 23 other states, the District of Columbia, and two governors, sued the Trump administration to block a new policy by the Administration for Children and Families (ACF) that would allow federal officials to access private records of millions of TANF recipients. The coalition argues the policy illegally shares sensitive personal data, including Social Security numbers and immigration status, with other federal agencies and private organizations, violating the Administrative Procedure Act and the Spending Clause. The lawsuit seeks to declare the policy illegal and block it from taking effect.

OR

Federal Communications Commission

Attorney General Rayfield and a coalition of 49 other attorneys general sent a letter to the FCC urging it to strengthen its Know Your Customer (KYC) rules to combat illegal robocalls. The coalition recommends requiring providers to understand customers' business, applying KYC standards to all providers, and collecting additional information on high-risk customers. No monetary penalty was imposed.