Open Records Decision No. 244
June 18, 1980

Re:  Whether student rosters are required to be disclosed under the Open Records Act.

Dr. Jack Elsom, President
Ranger Junior College
College Circle
Ranger, Texas  76470

Dear Dr. Elsom:

	You have requested our opinion as to whether student rosters must be disclosed 
under the Open Records Act, article 6252-17a, V.T.C.S.  A newspaper has requested the 
names of each student enrolled in certain courses currently offered at Ranger Junior 
College, and, for every such course, the names of the students present on each class day.

	Section 14(e) of the Open Records Act provides:

Nothing in this Act shall be construed to require the release of 
information contained in education records of any educational 
agency or institution except in conformity with the provisions of the 
Family Educational Rights and Privacy Act of 1974, as enacted by 
Section 513 of Public Law 93-380, codified as Title 20 U.S.C.A. 
Section 1232g, as amended.

	The Family Educational Rights & Privacy Act of 1974 [hereinafter called the 
Buckley Amendment] prohibits, with certain exceptions, the disclosure of any education 
record to anyone other than the student who is the subject of the record.  One exception 
is for “directory information,” which may be disclosed after compliance with federal 
notice requirements which afford affected students the right to object to the release of 
directory information relating to them.  20 U.S.C. § 1232g(a)(5); 45 C.F.R. § 99.37(c) 
(1976).  “Directory information” is defined as

. . . the student's name, address, telephone number, date and place of 
birth, major field of study, participation in officially recognized 
activities and sports, weight and height of members of athletic 
teams, dates of attendance, degrees and awards received, the most 
previous educational agency or institution attended by the student, 
and other similar information.

45 C.F.R. § 99.3 (1976) (emphasis added).

	This office has held that “directory information” includes a list of names and 
addresses of the parents of students at a particular institution, Open Records Decision No. 
96 (1975); a list of names and addresses of all former students credited with funds in 
their general property deposits, Open Records Decision No. 151 (1977); and the names 
of students assigned particular parking permit numbers, Open Records Decision No. RQ-
278 (1980).  The appropriate federal agency has advised us that, under guidelines issued 
by the Secretary of Education, the type of information requested here could reasonably 
constitute directory information.

	In our opinion, student rosters as described herein constitute directory 
information.  Accordingly, the University, after complying with federal notice 
requirements for the release of directory information, is required to disclose the 
information to which no appropriate objection has been filed pursuant to federal law.  
See Open Records Decision No. 96 (1975).

Very truly yours,

Mark White
Attorney General of Texas

John W. Fainter, Jr.
First Assistant Attorney General

Ted L. Hartley
Executive Assistant Attorney General

Prepared by Rick Gilpin
Assistant Attorney General

APPROVED:
OPINION COMMITTEE

C. Robert Heath, Chairman
Susan Garrison
Rick Gilpin
Laura Martin
Bruce Youngblood