Garlick v. Oak Park and River Forest High School District 200

In Garlick v. Oak Park and River Forest High School District 200, No. 1-06-1442, (2008), plaintiff's daughter, Keri, was not permitted to write on her Honors Biology test booklet; she was told to record her name and answers only on a scantron answer sheet. The Court noted "the only issue before the Court is whether the definition of student record contained in the Act covers test booklets with no student markings or other identifying information." The Court held "a test book devoid of student marks or other identifying information neither concerns an individual student nor individually identifies a student, and thus cannot constitute a student record within the meaning of the Act." The Court said, "a test book devoid of student marks or other identifying information neither concerns an individual student nor individually identifies a student, and thus cannot constitute a student record within the meaning of the Act." When student markings or other identifying information are present on the test booklets, however, the booklets become a student record subject to a parent's right to inspect and copy them under the Act. Redaction cannot change that.