Grove City College v. Bell

Section 901(a) of Title IX of the Education Amendments of 1972 prohibits sex discrimination in any educational program or activity that receives federal financial assistance. Title IX also directs federal agencies to promulgate regulations to ensure compliance with the statute and allows agencies to terminate funding for any noncompliant institutional program or part thereof. Grove City College (college) (plaintiff) was a private college that sought to avoid federal oversight by refusing to accept financial assistance from the federal government. The college did not participate in any direct institutional-aid programs, nor did it participate in any federal student-aid programs that would require the college to make decisions about a student’s eligibility for aid. However, the college accepted and enrolled numerous student recipients of federal Basic Educational Opportunity Grants (grants). The college declined to participate in the Regular Disbursement System (RDS), pursuant to which grant funds are sent directly to a school and which evaluates student eligibility and disburses grant funds. Instead, the college participated in the Alternative Disbursement System (ADS), pursuant to which the federal government disburses grant funds directly to students. The Department of Education requested that the college execute an Assurance of Compliance with Title IX. The college refused to execute the document and filed an action for declaratory judgment to ascertain, among other things, whether Title IX applied to the college and, if so, which of the college’s departments or programs was a recipient of federal financial assistance. The district court found that the college was not subject to Title IX. The court of appeals reversed. The United States Supreme Court granted certiorari. The Court first determined that the college had accepted indirect federal funding and was therefore subject to Title IX. The Court then considered which of the college’s programs or activities received federal assistance through the student grants.