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Law School Case Brief

Franklin v. Gwinnett Cty. Pub. Sch. - 503 U.S. 60, 112 S. Ct. 1028 (1992)

Rule:

Title IX of the Education Amendments of 1972, 20 U.S.C.S. §§ 1681-1688 is enforceable through an implied right of action. The question of what remedies are available under a statute that provides a private right of action is "analytically distinct" from the issue of whether such a right exists in the first place.

Facts:

Petitioner Christine Franklin, a student in a high school operated by respondent Gwinnett County Public Schools, a school district in the state of Georgia, filed an action for damages in Federal District Court under Title IX of the Education Amendments of 1972, alleging, inter alia, that she had been subjected to continual sexual harassment and abuse by a teacher, Andrew Hill. After the complaint was filed, Hill resigned on the condition that all matters pending against him be dropped, and the school district thereupon closed its investigation. After the school district argued that Title IX only provided equitable relief, the District Court dismissed the complaint on the ground that Title IX does not authorize an award of damages, the judgment of which the Court of Appeals for the Eleventh Circuit affirmed. Franklin sought certiorari review.

Issue:

Is money damages authorized under Title IX of the Education Amendments of 1972, 20 U.S.C.S. §§ 1681-1688?

Answer:

Yes

Conclusion:

The Supreme Court reversed the judgment and remanded the case. In so doing, the Court held that (1) Title IX provided a damages remedy for the student because the Court presumed the availability of all appropriate remedies unless the United States Congress had expressly indicated otherwise, and (2) where liability was created by statute without a remedy, it would have been enforced by a common law action.

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