Grove City College, a private, coeducational liberal arts school, sought to preserve its institutional autonomy by consistently refusing state and federal financial assistance. The College did, however, enroll a large number of students who received Basic Educational Opportunity Grants (BEOG's) through a Department of Education-run program. The DOE concluded that this assistance to students qualified the College as a recipient of federal assistance and made it subject to the nondiscrimination requirements of Title IX of the Education Amendments of 1972. When the College refused to comply with the requirements, the DOE attempted to terminate assistance to the student financial aid program. The College challenged the DOE's actions.
Was Grove City College subject to federal requirements because its students received federal grants? Did the provisions of Title IX violate the First Amendments rights of the College?
The Court held that there was no "substantive difference" between institutional assistance and aid received by a school through its students; Title IX coverage, the Court found, was triggered by the BEOG's. The Court noted that the assistance did not trigger institutionwide coverage under the Amendments, however. Only the College's financial aid program was subject to the federal requirements. The Court concluded that prohibiting discrimination as a condition for federal assistance did not infringe upon the First Amendment rights of the College and that the school was free to end its participation in the grant program.
Decisions
Decision: 7 votes for Bell, 2 vote(s) against Legal provision: Education Amendments of 1972
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Full Opinion by Justice Byron R. White
