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Keywords

lawsuitstatuteappealdiscriminationlegislative intent

lawsuitappealdiscriminationrespondent

Related Cases

Cannon v. University of Chicago, 441 U.S. 677, 99 S.Ct. 1946, 60 L.Ed.2d 560, 19 Empl. Prac. Dec. P 9202

Facts

The petitioner, a female, was denied admission to the medical education programs of two private universities, which were receiving federal financial assistance at the time. She alleged that her exclusion was based on her gender, thus violating Title IX of the Education Amendments of 1972. The District Court dismissed her complaint, stating that Title IX did not expressly authorize a private right of action, a conclusion that was upheld by the Court of Appeals.

Petitioner's complaints allege that her applications for admission to medical school were denied by the respondents because she is a woman.

Issue

Whether a private right of action exists under Title IX of the Education Amendments of 1972 for individuals alleging sex discrimination in educational programs receiving federal financial assistance.

Rule

Title IX prohibits sex discrimination in educational programs receiving federal financial assistance, and courts must analyze specific factors to determine if a private right of action can be implied.

Section 901(a) of Title IX of the Education Amendments of 1972 (Title IX) provides in part that '[n]o person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance.'

Analysis

The Supreme Court analyzed the four factors established in Cort v. Ash to determine if Congress intended to create a private remedy under Title IX. The Court found that Title IX was enacted for the benefit of individuals discriminated against based on sex, that legislative history indicated an intent to create a private cause of action, and that implying such a remedy would not frustrate the legislative scheme. The Court concluded that all factors supported the implication of a private right of action.

Our review of those factors persuades us, however, that the Court of Appeals reached the wrong conclusion and that petitioner does have a statutory right to pursue her claim that respondents rejected her application on the basis of her sex.

Conclusion

The Supreme Court reversed the decision of the Court of Appeals, holding that the petitioner may maintain her lawsuit under Title IX despite the absence of express authorization for it in the statute.

The judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion.

Who won?

The petitioner prevailed in the case because the Supreme Court recognized her right to pursue a private cause of action under Title IX, which was supported by the legislative intent and the statutory framework.

Petitioner may maintain her lawsuit, despite the absence of any express authorization for it in Title IX.

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