The parents of an American student who died on a study abroad program cannot sue the university, the Georgia Court of Appeals has ruled.

Erik Downes, 20, of Fort Myers, Florida, was a junior at Oglethorpe University when he traveled to Costa Rica with five other students and two professors for a 12-day academic trip. He disappeared under a wave on Jan. 4, 2011. A student who tried to help him said he was pulled out to sea by a current. His body was found three days later.