## Facts

- Jacqueline Lantz, a 16-year-old student at Lincoln High School in Yonkers, New York, sought to try out for the junior varsity football team because the school had no girls’ football team.
- A New York education regulation barred mixed competition in specified sports, including football, and was applied to prevent her from trying out.
- The challenged rule, 8 N.Y.C.R.R. § 135.4(c)(7)(ii)(c)(2), stated there shall be no mixed competition in football and other listed contact sports.
- Lantz, by her next friend, sued state education officials, the Board of Regents, the Yonkers Board of Education, and the state high school athletic association under 42 U.S.C. § 1983.
- She alleged violations of Title IX and the Fourteenth Amendment’s Equal Protection Clause and sought declaratory and injunctive relief and attorney’s fees.
- The court consolidated the preliminary-injunction hearing with a trial on the merits.

## Issues

1. Whether New York’s categorical ban on mixed-sex participation in football violated Title IX’s prohibition on sex discrimination in federally funded education programs.
2. Whether the categorical exclusion of girls from trying out for football violated the Equal Protection Clause.

## Decision

- The court held the regulation did not violate Title IX because federal law and implementing regulations did not require mixed-sex participation in contact sports such as football.
- The court held the regulation violated the Equal Protection Clause because it categorically excluded all female students from football tryouts based solely on sex.
- The court declared the rule unconstitutional to the extent it barred girls from trying out for football and granted relief allowing Lantz an equal opportunity to compete for a roster spot.

## Legal Principles

- Title IX does not, by itself, require coeducational teams in contact sports; it may permit sex-separated participation structures for such sports.
- Sex-based classifications by the state are subject to intermediate scrutiny: they must serve important governmental objectives and be substantially related to achieving those objectives.
- Safety and competitive concerns may be important governmental objectives in school athletics, but a blanket sex-based exclusion that does not permit individualized assessment is not substantially related to those objectives.
- Equal protection forbids rules grounded in generalizations about the abilities or vulnerability of an entire sex when individuals could be evaluated by ability and safety on equal terms.

## Conclusion

The court rejected a Title IX challenge to New York’s no-mixed-competition football rule but held that equal protection prohibits a categorical bar that prevents all girls from trying out; the state must allow female students an equal chance to compete, subject to non-discriminatory, individualized standards.


Lantz ex rel. Lantz v. Ambach, 620 F. Supp. 663 (S.D.N.Y. 1985)