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FERPA Unconstitutional?

The executive director of a group that provides legal support and education for student journalists has posted an interesting analysis arguing that the Supreme Court's invalidation of the Medicaid expansion requirements in the Affordable Care Act should be interpreted as making FERPA unconstitutional. Since I'm not a scholar of constitutional law (as I told my father when I graduated with my baccalaureate, I'm a conscientious objector when it comes to going to law school), I won't hazard a guess as to the validity of the gentleman's analysis. I'm looking forward to seeing, though, if any of EDUCAUSE's friends in the legal community take a look at this issue and have a contrary opinion.