Grove City College v. Bell
Grove City College v. Bell is a significant Supreme Court case from 1984 that addressed the application of Title IX of the Education Amendments of 1972, which prohibits gender discrimination in educational institutions receiving federal funding. The Court ruled in a 6-3 decision that Title IX applied to Grove City College, despite the institution itself not directly receiving federal funds, due to the presence of students utilizing federal grants. This decision was pivotal as it clarified the conditions under which schools could be held accountable for compliance with Title IX. The ruling sparked considerable backlash from civil rights and women's advocacy groups, leading to the enactment of the 1987 Civil Rights Restoration Act. This legislation aimed to reinforce the application of Title IX, ensuring that any program within an institution that received federal funding had to be free from discrimination. The case and its aftermath reflect ongoing debates about gender equity in education and the extent of federal oversight in private institutions.
Grove City College v. Bell
Date: February 28, 1984
Citation: 465 U.S. 555
Issue: Sex discrimination
Significance: The Supreme Court banned sex discrimination in postsecondary schools receiving federal funds.
Justice Byron R. White wrote the opinion for the Supreme Court for this 6-3 decision in which there was a wide, conflicting array of dissents and concurrences. This ruling declared that Title IX of the 1972 Educational Amendments to the 1964 Civil Rights Act banned gender discrimination in postsecondary schools receiving federal funds. Although Grove City College did not receive federal funds, enough students attended the college under the Basic Educational Opportunity Grants to justify the school’s inclusion under Title IX. The Justice Department’s original position was that all Grove City’s programs needed to comply with Title IX before the school received any federal funds; however, when President Jimmy Carter was replaced by the more conservative Ronald Reagan, the government’s stance against Grove City softened. The 1984 Court ruling did not broadly cut off funds to all programs but only those that were discriminatory. Civil rights and women’s groups reacted strongly. Their efforts resulted in the passage of the 1987 Civil Rights Restoration Act over Reagan’s veto to correct the Grove City ruling. The act applied Title IX if any part of the institution received federal funding and mandated that all programs be free from discrimination.
