Sreedhar v. National Institute of Technology Karnataka
- Laura Swain
- 1:25-cv-03100
- U.S. District Court · Southern District of New York
- 4
In Sreedhar v. National Institute of Technology Karnataka, Judge Swain dismissed a FERPA suit because FERPA provides no private lawsuit and funding allegations were absent.
Srikant Sreedhar’s FERPA complaint against the National Institute of Technology Karnataka and Mangalore University was dismissed; the court also denied him fee-free status for an appeal.
What happened
In Sreedhar v. National Institute of Technology Karnataka, Srikant Sreedhar sued the National Institute of Technology Karnataka and Mangalore University under the Federal Education Rights and Privacy Act (FERPA). He alleged that his marks were displayed online without consent and also alleged forgery, falsified records, stalking, privacy violations, and murder.
The court explained that FERPA does not let individuals file private lawsuits for alleged education-record privacy violations. It also noted that both defendants are located in India and that the complaint did not allege they receive federal funding, which FERPA requires for its provisions to apply. The court found that the defects could not be fixed by amendment.
Judge Laura Taylor Swain dismissed the complaint under the federal screening law for people proceeding without paying filing fees, denied leave to amend, directed the Clerk to terminate all pending motions, and denied fee-free status for any appeal.
The detailed version
- Sreedhar v. National Institute of Technology Karnataka · No. 1:25-cv-03100
- Laura Swain
- Apr. 29, 2025
Background
Srikant Sreedhar, appearing without a lawyer, filed a 132-page complaint against the National Institute of Technology Karnataka and Mangalore University under the Federal Education Rights and Privacy Act (FERPA), 20 U.S.C. § 1232g. The court had allowed him to proceed without prepaying filing fees. Both defendants are located in India.
Sreedhar alleged that his marks were displayed on the internet without his consent. He also alleged forgery, falsified transcripts and meeting minutes, stalking, privacy violations, and murder. He sought, among other relief, an order protecting his internet privacy. After filing the complaint, he submitted multiple motions seeking various forms of relief.
Court’s Analysis
The court applied the screening requirement for complaints filed without prepaying fees. Under that requirement, the court must dismiss a complaint that is frivolous, malicious, fails to state a claim for relief, or seeks monetary relief from an immune defendant. The court must also dismiss a case when it lacks subject-matter jurisdiction. Although courts read complaints filed without lawyers generously, those complaints still must provide enough facts to make a legally valid claim plausible.
The court held that FERPA does not create a private right of action, meaning that an individual cannot sue directly under FERPA for an alleged violation of education-record privacy. FERPA instead conditions federal funding for schools on compliance with its nondisclosure provisions and provides for federal administrative enforcement.
The court also stated that FERPA applies only to institutions receiving federal funding. The complaint did not allege that either defendant receives federal funding. For those reasons, the court concluded that Sreedhar could not maintain a FERPA action against the defendants.
Disposition
The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii). It declined to grant leave to amend because it found that the complaint’s defects could not be cured by amendment. The Clerk of Court was directed to terminate all pending motions and enter judgment.
The court also certified that any appeal would not be taken in good faith and denied Sreedhar the ability to proceed without prepaying fees for an appeal. The opinion does not state that the dismissal was with or without prejudice.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.