## Facts

- Christine Franklin attended North Gwinnett High School, operated by Gwinnett County Public Schools, a recipient of federal education funds.
- Franklin alleged that beginning in 1986 a teacher and coach, Andrew Hill, subjected her to repeated sexual harassment and abuse in school settings.
- She alleged school officials knew of the conduct, failed to take effective action, and discouraged her from pursuing charges.
- Hill resigned after the complaint, allegedly conditioned on dropping matters against him, and the school ended its investigation.
- Franklin sued under Title IX seeking monetary damages; the district court dismissed, and the Eleventh Circuit affirmed on the ground that Title IX did not authorize damages.

## Issues

1. Whether the implied private right of action under Title IX permits an award of monetary damages for intentional discrimination.

## Decision

- The Supreme Court unanimously reversed and remanded.
- The Court held that monetary damages are available as “appropriate relief” in a private action to enforce Title IX.
- The Court reasoned that, absent clear congressional direction to the contrary, federal courts may award all appropriate relief for a proven statutory violation.
- A concurrence agreed that damages are available, while emphasizing that courts may also imply remedial limits when the cause of action itself is judicially implied.

## Legal Principles

- When a federal statute is enforceable through a private cause of action, courts presume the availability of “any appropriate relief” unless Congress clearly restricts remedies.
- Title IX’s implied private right of action includes monetary damages for intentional violations.
- The absence of effective prospective relief for completed injuries supports damages as an appropriate remedy under Title IX.

## Conclusion

The Court held that private plaintiffs enforcing Title IX may recover monetary damages for intentional discrimination, rejecting the view that only equitable or prospective remedies are available.


Franklin v. Gwinnett Cnty. Pub. Schs., 503 U.S. 60 (1992)