Narrative Opinion Summary
In this case, a male applicant challenged the admissions policy of a private college that exclusively admits women, alleging violations of his Fourteenth Amendment rights under 42 U.S.C. § 1983 and Title IX of the Civil Rights Act of 1964. The plaintiff contended that the college's policy constituted state action due to tax exemptions and financial aid received from the government. However, the court granted the defendants' motion for summary judgment, ruling that the college's actions did not amount to state action under § 1983, as the financial support and tax exemptions did not demonstrate government control over the admissions policy. Additionally, the court found that Title IX's prohibition of sex discrimination in federally funded education programs does not extend to admissions at private undergraduate institutions like the college in question. The court relied on existing regulations by the Department of Health, Education and Welfare, which exclude undergraduate institutions from the definition of 'professional education' programs under Title IX. Consequently, the court dismissed the plaintiff's claims due to lack of subject matter jurisdiction and failure to establish a violation under Title IX, affirming the college's female-only admissions policy.
Legal Issues Addressed
Regulatory Interpretation under 20 U.S.C. 1682subscribe to see similar legal issues
Application: The court upheld the Department of Health, Education and Welfare's regulation defining 'institution of professional education' and found it excluded Alverno College.
Reasoning: HEW's regulation, 45 C.F.R. 86.2(n), defines an 'institution of professional education' as one that offers a program leading to a first professional degree, excluding undergraduate institutions.
State Action Requirement under 42 U.S.C. § 1983subscribe to see similar legal issues
Application: The court determined that Alverno College's admissions policy did not constitute state action as required for a claim under 42 U.S.C. § 1983.
Reasoning: The court reviewed the defendants' motion for summary judgment, focusing on whether Alverno College's actions constituted state action necessary for jurisdiction under § 1983.
Tax Exemptions and State Actionsubscribe to see similar legal issues
Application: The plaintiff argued that tax exemptions equate to state action; however, the court found this argument insufficient to establish state action.
Reasoning: The plaintiff's argument that tax exemptions create state action lacks distinction from prior cases like Musso, Cannon, and Cohen, which have consistently ruled that such exemptions do not equate to state action.
Title IX Applicability to Private Undergraduate Institutionssubscribe to see similar legal issues
Application: The court held that Title IX does not apply to admissions policies of private undergraduate institutions, such as Alverno College.
Reasoning: Regarding Title IX, which prohibits sex discrimination in federally funded education programs, it does not apply to admissions at private undergraduate institutions like Alverno.