With no explanation, chose the best option from "A", "B", "C" or "D". action, Tab 2, Exhibit 13, J.A. 175. The Miami University Disciplinary Board Summary occasionally reflects this mutuality. See, e.g., Tab 2, Exhibit 14, J.A. 177, 178, 179, 184. 24 . Even if a qualified First Amendment right of access attached to these proceedings, which it clearly does not, the common law recognizes various exceptions to the right of access including certain privacy rights of participants or third parties. Brown & Williamson Tobacco Corp., 710 F.2d at 1179 (citing Nixon v. Warner Communications, Inc., 435 U.S. 589, 598, 98 S.Ct. 1306, 55 L.Ed.2d 570 (1978)). These privacy rights are of particular import when recognized and protected by federal statutory provisions like the FERPA. See In re The Knoxville News-Sentinel Co., Inc., 723 F.2d 470, 476 (6th Cir.1983)

A: holding prisoners had no clearly established right to privacy in medical records in 1995
B: recognizing a constitutional right of privacy in mental health records
C: holding that records relating to a student court were not education records
D: holding that it was appropriate to seal banking records when congress clearly mandated the privacy of those records
D.