## Facts

- Geraldine G. Cannon, a 39-year-old applicant, was denied admission to the University of Chicago’s medical school and Northwestern University Medical School.
- Both schools received federal financial assistance.
- Cannon alleged the schools used age-based admissions policies that largely excluded applicants over 30 (and, at Northwestern, categorically excluded applicants over 35).
- She claimed these policies had a disparate impact on women and constituted sex discrimination in admissions.
- Cannon sued under Title IX of the Education Amendments of 1972, which bars sex discrimination in federally funded education programs.

## Issues

1. Whether Title IX implies a private cause of action permitting an individual to sue a federally funded educational institution for alleged sex discrimination, despite no express statutory authorization.
2. Whether Title IX’s administrative enforcement mechanism (including potential termination of federal funds) indicates Congress intended that mechanism to be exclusive.

## Decision

- The Supreme Court reversed, holding (6–3) that Title IX contains an implied private right of action.
- The Court applied the four-factor test from *Cort v. Ash* to infer congressional intent to allow private suits.
- The Court concluded Cannon was within the class Title IX was enacted to protect—persons discriminated against on the basis of sex.
- The Court found legislative history and Congress’s enactment against the backdrop of Title VI case law supported an inference that Congress expected private enforcement.
- The Court rejected the view that administrative fund-termination procedures were the exclusive means of enforcing Title IX.
- The Court held implying a private remedy was consistent with Title IX’s purposes and did not improperly intrude on matters reserved to the States.

## Legal Principles

- A private right of action may be implied from a federal statute when congressional intent to provide a judicial remedy is indicated under the *Cort v. Ash* factors.
- Title IX’s prohibition on sex discrimination in federally funded education programs is enforceable through private civil suits, even without an express authorization provision.
- The existence of an administrative enforcement scheme (including termination of federal funds) does not, by itself, preclude private enforcement when private suits further statutory objectives.
- Congress’s enactment of a statute modeled on another law with an understood private remedy, together with related legislative signals (such as fee-shifting provisions), may support inferring a comparable private remedy.

## Conclusion

The Court recognized an implied private right of action under Title IX, allowing individuals to sue federally funded educational institutions for alleged sex discrimination and rejecting the view that administrative fund-termination procedures are the exclusive enforcement method.


Cannon v. University of Chicago, 441 U.S. 677 (1979)