National Collegiate Athletic Association v. Smith

Renee Smith (plaintiff) completed her undergraduate degree in two and a half years and then enrolled in graduate school at a different institution, where she sought to continue playing intercollegiate volleyball. The National Collegiate Athletic Association (NCAA) (defendant) denied Smith’s eligibility under its rule allowing graduate students to play only at the institution where they earned their undergraduate degree. Smith requested a waiver, which the NCAA denied. Smith sued the NCAA under Title IX of the Education Amendments of 1972, which prohibits sex discrimination in any education program or activity receiving federal financial assistance, arguing that the NCAA granted more waivers to male than female athletes. The NCAA moved to dismiss, arguing that it was not subject to Title IX because it was not a recipient of federal financial assistance. Smith countered that the NCAA governed federally funded programs and benefited economically from member institutions’ receipt of federal funds. The district court dismissed the complaint, finding the NCAA’s ties to federal funding too attenuated. It also denied Smith’s motion to amend her complaint. The Third Circuit reversed that denial, holding that the NCAA’s receipt of dues from federally funded member institutions could bring it within the scope of Title IX. The United States Supreme Court granted certiorari.