Changes

U.S. Civil Rights Commission Investigates College Admission Bias|first=Zach|last=Miners|date=November 18, 2009|accessdate=August 30, 2012}}</ref>

U.S. Civil Rights Commission Investigates College Admission Bias|first=Zach|last=Miners|date=November 18, 2009|accessdate=August 30, 2012}}</ref>

==Private cause of action==

==Private cause of action==

Title IX contain an explicit provision allowing for private lawsuits. However, Congress later enacted the Civil Rights Attorney's Fees Awards Act of 1976, 90 Stat. 2641, which authorizes an award of fees to prevailing private parties in actions to enforce Title IX as well as other Civil Rights laws.  So, the courts have interpreted Title IX as allowing plaintiffs to sue educational institutions for monetary damages and other relief in addition to the enforcement efforts of the Office of Civil Rights of the United States Department of Education.  The Supreme  Court held in ''Cannon v. University of Chicago'', [http://www.law.cornell.edu/supremecourt//text/441/677 441 U.S. 677, 99 S.Ct. 1946, 60 L.Ed.2d 560 (1979),] that Title IX is also enforceable through an implied private right of action. In ''Franklin v. Gwinnett County Public Schools'', [http://www.law.cornell.edu/supremecourt//text/503/60 503 U.S. 60, 112 S.Ct. 1028, 117 L.Ed.2d 208 (1992),] the Court established that monetary damages are available in private Title IX suits. Private lawsuits have been successful in a number of contexts:

Title IX does not contain an explicit provision allowing for private lawsuits. However, Congress later enacted the Civil Rights Attorney's Fees Awards Act of 1976, 90 Stat. 2641, which authorizes an award of fees to prevailing private parties in actions to enforce Title IX as well as other Civil Rights laws.  So, the courts have interpreted Title IX as allowing plaintiffs to sue educational institutions for monetary damages and other relief in addition to the enforcement efforts of the Office of Civil Rights of the United States Department of Education.  The Supreme  Court held in ''Cannon v. University of Chicago'', [http://www.law.cornell.edu/supremecourt//text/441/677 441 U.S. 677, 99 S.Ct. 1946, 60 L.Ed.2d 560 (1979),] that Title IX is also enforceable through an implied private right of action. In ''Franklin v. Gwinnett County Public Schools'', [http://www.law.cornell.edu/supremecourt//text/503/60 503 U.S. 60, 112 S.Ct. 1028, 117 L.Ed.2d 208 (1992),] the Court established that monetary damages are available in private Title IX suits. Private lawsuits have been successful in a number of contexts:

In ''Franklin'', a female high school student had been sexually harassed and abused by her male teacher.  Although the teacher resigned on the condition that all claims against him be dropped, the suit continued against the school district for monetary damages.  In [http://www.law.cornell.edu/supremecourt/text/96-1866/#writing-ZS ''Gebser v. Lago Vista Independent School District'',  524 U.S. 274(1998),] a female high school student had a sexual relationship with a male teacher, who was arrested when the school authorities found out.  The student then sued the school district for money damages, but the Supreme Court held that damages could only be awarded if a supervisor in the school knew of the abuse, had the power to end it, but failed to do so.  In ''Davis v. Monroe County Board of Education'', [http://www.law.cornell.edu/supct/html/97-843.ZO.html 526 U.S. 629 (1999)] the Supreme Court held that if a school was "deliberately indifferent" to student-on-student sexual harassment, it would be liable for damages under Title IX.  In ''Davis'', a fifth grade boy was repeatedly harassing a girl student with the teachers and principal ignoring her parents' complaints.

In ''Franklin'', a female high school student had been sexually harassed and abused by her male teacher.  Although the teacher resigned on the condition that all claims against him be dropped, the suit continued against the school district for monetary damages.  In [http://www.law.cornell.edu/supremecourt/text/96-1866/#writing-ZS ''Gebser v. Lago Vista Independent School District'',  524 U.S. 274(1998),] a female high school student had a sexual relationship with a male teacher, who was arrested when the school authorities found out.  The student then sued the school district for money damages, but the Supreme Court held that damages could only be awarded if a supervisor in the school knew of the abuse, had the power to end it, but failed to do so.  In ''Davis v. Monroe County Board of Education'', [http://www.law.cornell.edu/supct/html/97-843.ZO.html 526 U.S. 629 (1999)] the Supreme Court held that if a school was "deliberately indifferent" to student-on-student sexual harassment, it would be liable for damages under Title IX.  In ''Davis'', a fifth grade boy was repeatedly harassing a girl student with the teachers and principal ignoring her parents' complaints.