Grove City College v. Bell

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465 U.S. 555 (1984), argued 29 Nov. 1983, decided 28 Feb. 1984 by vote of 6 to 3; White for the Court, Powell concurring in part and dissenting in part, Brennan, joined by Marshall and Stevens, concurring in part and dissenting in part. In this case the Court found that Title IX of the Education Amendments of 1972 prohibited gender discrimination in colleges and universities that receive federal funds. Grove City College's enrollment of students who received Basic Educational Opportunity Grants from the federal government was found sufficient to trigger Title IX, although the college, as a matter of principle, received no other federal funds. But the sanction of Title IX—the cutoff of federal funds—was limited to the discriminatory program and could not be applied to any other programs at the school. Thus, under the Court's ruling a university that discriminated against women could continue to receive federal funding so long as specific discriminatory programs did not.

Reaction to Grove City was immediate. Civil rights and women's groups were outraged by the decision. So too were many members of Congress who saw this case as a prime example of the weakening of the Reagan administration's civil rights commitment. Grove City originally had been filed by the Justice Department under the Carter Administration. It took the position that Grove City College was not in compliance with Title IX because all programs needed to comply in order for a school to have funding eligibility. However, when the case reached the Supreme Court the Reagan Administration Justice Department retreated from that position to one urging only a limited cutoff of funding.

In 1987, over the veto of President Ronald Reagan, Congress enacted the Civil Rights Restoration Act to overturn Grove City. The bill specified that Title IX applies to any college or university if any part of the institution receives federal assistance. Thus, all of the university's federal funds are now at risk even if there is proven discrimination in only one program.

Karen O’Connor

Subjects: Law.

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