Grove City College v. Bell
Headline: Title IX applies when students receive federal grants; Court upheld Department power to cut off student grants to force a college to sign a compliance assurance, affecting colleges and students.
Holding: The Court affirmed that the Department could terminate BEOGs received by Grove City students to compel the College to sign a Title IX Assurance, and that Title IX applies to the College's student financial aid program.
- Allows agencies to withhold student grants to enforce Title IX assurances.
- Makes college student-aid offices subject to Title IX compliance demands.
- Forces affected students to take grants elsewhere or attend without federal aid.
Summary
Background
Grove City College is a private liberal arts school that refused any direct federal aid but enrolled students who received federal Basic Educational Opportunity Grants (BEOGs). The Department of Education required the College to sign an Assurance of Compliance with Title IX; the College refused and the Department moved to suspend the students' BEOGs to obtain that assurance.
Reasoning
The Court decided that Title IX covers programs that receive federal money even when the money reaches a school through students. It held that the relevant covered program at Grove City is the college's student financial aid program, not the entire institution. The Court also ruled that the Department may condition continued BEOG funding on a program-specific Assurance of Compliance and may terminate assistance for refusal to sign, without a prior finding of actual discrimination.
Real world impact
As a practical matter, the decision lets federal agencies require schools that benefit from student aid to promise nondiscrimination in the federally assisted program and to enforce that promise by withholding student grants. Students can either move their grants to other schools or attend without federal aid; the College may opt out of the programs altogether.
Dissents or concurrances
Justices Powell and others joined but expressed unease about federal overreach. Justice Stevens warned Part III was advisory and fact-dependent. Justice Brennan (joined by Justice Marshall) agreed BEOGs trigger coverage but dissented from limiting coverage to only the financial aid program, arguing federal aid that benefits the whole college should reach the entire institution.
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