FERPA's design has always contained a structural contradiction: it creates privacy rights for students while providing no mechanism for students to enforce those rights themselves. The Department of Education holds the theoretical power to withdraw federal funding from violating institutions, but that power has functioned as deterrence theater — invoked as threat, never executed as consequence. What this means in practice is that a student with documented violations must translate their claim into a civil rights or negligence theory that a private attorney will find economically viable. When the defendant…