The Board of Education of the Jefferson City Public School District Missouri Cases

Tammy Ferry, a tenured teacher, was terminated by the Jefferson City Public School District's Board of Education for transferring confidential student information to her personal Google account. The circuit court reversed the Board's decision, finding no "disclosure" under FERPA. The Missouri Supreme Court vacated the circuit court's judgment, holding that Ferry's actions constituted a prohibited disclosure from the District to herself and a willful violation of board policy, thus authorizing her termination under the Teacher Tenure Act.

Tammy Ferry, a tenured teacher, was terminated by the Board of Education for allegedly violating FERPA and Board policy by transferring confidential student information to her personal Google account. The circuit court reversed the Board's decision, finding no unlawful disclosure. On appeal, the Western District affirmed the circuit court's judgment, holding that Ferry's transfer of files to herself did not constitute a "disclosure" under FERPA or Board policy, as disclosure requires communication to a third party.