Franklin v. Gwinnett County Public Schools

Supreme Court of the United States · 1992 · Federal Courts

Federal CourtsTitle IXImplied right of actionRemediesMonetary damagesTitle IXimplied right of actiondamages

Facts

Christine Franklin, a student at North Gwinnett High School, alleged that a teacher and coach, Andrew Hill, continually sexually harassed her and on three occasions subjected her to coercive intercourse. She also alleged that teachers and administrators became aware of and investigated Hill's harassment of Franklin and other female students, but took no action to stop it and discouraged her from pressing charges. Hill later resigned on the condition that pending matters against him be dropped, and the school closed its investigation. Franklin then brought this Title IX action seeking monetary damages.

Issue

Whether the implied right of action under Title IX recognized in Cannon v. University of Chicago supports a claim for monetary damages. More specifically, the question was whether damages are available at least for an alleged intentional violation of Title IX.

Rule

When a federal statute supports a private right of action, courts presume the availability of all appropriate remedies unless Congress has expressly indicated otherwise. Applying that principle to Title IX, damages are available in a private action to enforce Title IX for intentional violations absent clear congressional direction to the contrary.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Maya Torres attended a publicly funded technical college in Phoenix, Arizona. She alleges that the college intentionally removed her from a competitive training program because she complained that male students were being favored, and she sues under Title IX seeking compensatory damages after she has already graduated.

How should the court rule on the college's argument that damages are unavailable because Title IX does not expressly mention money damages?

Explanation. The majority held that where a federal statute supports a private right of action, federal courts presume the availability of all appropriate remedies unless Congress has expressly indicated otherwise. Applying that rule to Title IX, damages are available for intentional violations absent clear congressional direction to the contrary. The Court did not require an express damages provision or resolution of Title IX's constitutional source.