North Haven Bd. of Educ. v. Bell (1981)
- Docket
- 80-986
- Decided
- 1981-01-01
Summary
Question: Is Title IX’s prohibition on gender discrimination in schools intended to cover the employees of schools? Conclusion: Yes. Justice Harry A. Blackmun delivered the opinion for the 6-3 majority. The Court held that, while Title IX does not expressly include employees, Congress’s choice of words, i.e. “no person” as opposed to “student” or “beneficiary”, implies an intention to broadly cover individuals involved in educational institutions rather than only students. The legislative history of Title IX supports the inference that Congress intended Title IX to prohibit gender discrimination of employees. Additionally, Congress was given the opportunity to view HEW’s regulations and pass a resolution of disapproval if the regulations were inconsistent with Title IX. While such a resolution concerning the employee discrimination regulation was introduced, it was not passed. Therefore, Congress appeared to intend Title IX to apply to employee discrimination, and the Department of Health, Education and Welfare’s regulations were valid. Justice Lewis F. Powell, Jr. wrote a dissent in which he argued that the language of Title IX, on its face, did not apply to employee discrimination. Legislative history can only override the language of a law if the legislative history is clear and unambiguous that Congress intended Title IX to apply to employee discrimination. In this case, the majority opinion relied primarily on the statements of one congressman when analyzing the legislative history, which is not sufficient to support the majority’s conclusion. Therefore Justice Powell held that Title IX did not apply to employee discrimination. Justice Warren E. Burger and Justice William H. Rehnquist joined in the dissent,