North Haven Board of Education v. Bell

Congress enacted Title IX of the Education Amendments of 1972, which prohibits gender discrimination by federally funded education programs. The law was written with two central provisions. The first, § 901(a), provided that “no person” will be discriminated against on the basis of sex by any education program or activity receiving federal funds. The statute enumerates nine exceptions to the coverage of this provision. The second, § 902, authorized agencies awarding federal funds to promulgate regulations ensuring compliance with the statute. Noncomplying programs could be punished with a loss of funding. After Title IX was enacted, the Department of Health, Education, and Welfare (HEW) issued regulations that interpreted the word “person” as used in § 901(a) to include employees of federally funded education programs. A teacher in the North Haven school district filed a complaint with HEW, alleging that the district had terminated her employment in violation of Title IX. In response to an investigation by HEW, the North Haven Board of Education (North Haven) (plaintiff) brought an action in federal district court, arguing that the HEW regulations exceeded the scope of Title IX and requesting that the court enjoin HEW from terminating New Haven’s federal funding. The district court granted New Haven’s motion for summary judgment. The court of appeals reversed. The United States Supreme Court granted certiorari.