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Keywords

damagesappealdiscrimination
damagesappealdiscrimination

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Lakoski v. James, 66 F.3d 751, 66 Empl. Prac. Dec. P 43,748, 103 Ed. Law Rep. 652

Facts

Issue

Rule

Title IX did not provide direct private right of action to individual seeking money damages for alleged sex discrimination by federally funded educational institution; to grant private right of action for damages under Title IX for employee actions for which private remedy was available under Title VII would be to disrupt carefully balanced remedial scheme for redressing employment discrimination.

Analysis

The court analyzed the relationship between Title IX and Title VII, concluding that Title VII's comprehensive remedial structure precludes individuals from seeking damages under Title IX for employment discrimination. The court emphasized that allowing such claims would undermine the administrative procedures established by Title VII, which was designed to address employment discrimination comprehensively.

We are not persuaded that Congress intended that Title IX offer a bypass of the remedial process of Title VII. We hold that Title VII provides the exclusive remedy for individuals alleging employment discrimination on the basis of sex in federally funded educational institutions.

Conclusion

The court reversed the district court's judgment, holding that Title VII provides the exclusive remedy for employment discrimination claims, and thus Dr. Lakoski could not pursue her claims under Title IX.

We hold that the district court erred in submitting Dr. Lakoski's Title IX claim for damages to the jury.

Who won?

The University of Texas Medical Branch prevailed in the appeal, as the court determined that Title IX does not allow for a private right of action for employment discrimination claims. The court emphasized that allowing such claims would disrupt the established remedial framework of Title VII, which was intended to be the exclusive means for addressing employment discrimination in federally funded educational institutions.

The University of Texas Medical Branch prevailed in the appeal, as the court determined that Title IX does not allow for a private right of action for employment discrimination claims.

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