Cannon v. University of Chicago
Citation and Court
441 U.S. 677 (1979) — Supreme Court of the United States
Facts
Geraldine Cannon was denied admission to medical schools at Northwestern University and the University of Chicago. She sued, alleging that the schools had discriminated against her on the basis of sex in violation of Title IX of the Education Amendments of 1972, which prohibits sex discrimination by federally funded educational programs. No express private right of action was provided in the statute.
Issue
Whether Title IX of the Education Amendments of 1972 contains an implied private right of action for individuals who suffer sex discrimination by federally funded educational institutions.
Holding
Yes. Title IX contains an implied private right of action, applying the four-factor test from Cort v. Ash to conclude that Congress intended to create such a right.
Rule / Doctrine
Implied private right of action under the Cort v. Ash four-factor test: (1) is the plaintiff a member of the class the statute was designed to benefit? (2) is there any indication of legislative intent to create or deny a private remedy? (3) is a private remedy consistent with the statute’s legislative scheme? (4) is the cause of action one traditionally relegated to state law?
Significance
Cannon is the landmark case recognizing an implied private right of action under Title IX and is the primary application of the Cort v. Ash framework. It also paved the way for subsequent development of Title IX remedies, including the holding in Franklin v. Gwinnett County Public Schools (1992) that monetary damages are available.