## Facts

- Title IX prohibits sex discrimination against any person “under any education program or activity receiving Federal financial assistance.”
- The federal education agency issued regulations interpreting Title IX to reach employment practices of federally funded educational institutions, including hiring, firing, and terms and conditions of employment.
- The North Haven and Trumbull Boards of Education, as federal-funds recipients, challenged the regulations as exceeding statutory authority to the extent they applied to employees rather than students.
- The Court of Appeals upheld the regulations as within the Secretary of Education’s authority.
- The Supreme Court granted certiorari and consolidated the cases to decide whether Title IX permits regulation of employment discrimination by federally funded schools.

## Issues

1. Whether Title IX’s prohibition of sex discrimination “under any education program or activity receiving Federal financial assistance” extends to employees of educational institutions, not only students.
2. Whether the Secretary of Education may promulgate and enforce Title IX regulations that prohibit sex discrimination in employment practices of federally funded educational institutions.

## Decision

- The Court held, 6–3, that Title IX covers employees as well as students.
- The Court upheld the validity of regulations applying Title IX to employment discrimination by recipients of federal education funds.
- The Court reasoned that the statutory term “no person” is broad and not limited to students or direct beneficiaries.
- The Court concluded that discrimination in employment can constitute discrimination “under” an education program or activity because employment is closely connected to the program’s operation and can affect educational quality and access.
- The Court gave weight to the responsible agency’s longstanding interpretation extending Title IX to employment.
- The Court rejected the argument that Title VII’s existence implied Title IX excludes employment coverage; overlapping remedies were treated as permissible.

## Legal Principles

- Title IX’s text (“no person” and “under any education program or activity receiving Federal financial assistance”) can encompass employment discrimination within federally funded education programs.
- Federal regulations may prohibit sex discrimination in employment practices of federally funded educational institutions when such practices occur within the scope of the covered program or activity.
- Longstanding, consistent administrative interpretations of a statute may be given substantial weight when assessing the validity of implementing regulations.
- The presence of other federal employment-discrimination statutes does not, by itself, negate Title IX’s application to employment in federally funded educational settings.

## Conclusion

The Court ruled that Title IX is not confined to student-related discrimination and authorizes federal enforcement against sex discrimination in employment by federally funded educational institutions, sustaining agency regulations that apply Title IX to employees’ workplace treatment.


N. Haven Bd. of Educ. v. Bell, 456 U.S. 512 (1982)