In U.S. v. Miami University (6th Cir. 2002) 294 F.3d 797, the United States, on behalf of the Department of Education, sued the university to permanently enjoin it from releasing student disciplinary records to a newspaper. In affirming the district court's decision to grant the injunction, the Sixth Circuit Court of Appeals reviewed the applicable portions of FERPA. The court found that FERPA's definition of "education records," cited immediately above, includes disciplinary records "because they directly relate to a student and are kept by that student's university. Notably, Congress made no content-based judgments with regard to its 'education records' definition." (Id. at p. 812.) The court then pointed to several exemptions from the confidentiality of student disciplinary records that "clearly evolve from a base Congressional assumption that student disciplinary records are 'education records' and thereby protected from disclosure." (U.S. v. Miami University, supra, 294 F.3d at p. 812.) First, the final results of any disciplinary proceeding may be disclosed to the alleged victim of a crime of violence or a nonforcible sex offense. (20 U.S.C. 1232g(b)(6)(A).) Second, such information may be disclosed to the general public when the disciplinary body determines that the student did commit such a crime. (20 U.S.C. 1232g(b)(6)(B).) Third, the disciplinary records of a student who poses a significant risk to himself or herself, or to other members of the school community, may be disclosed to persons having a "legitimate educational interest in the behavior of the student." (20 U.S.C. 1232g(h)(2).) Fourth, if a student under the age of 21 at an institution of higher learning commits a disciplinary violation involving alcohol or a controlled substance, then the institution may disclose such information to a parent or guardian. (20 U.S.C. 1232g(i)(1).) The court then concludes that "if Congress believed that student disciplinary records were not education records under the FERPA, then these sections would be superfluous." (U.S. v. Miami University, supra, at p. 813.) Thus, student disciplinary records are unquestionably student education records under federal law and are protected as such.