In Pell v. Trustees of Columbia Univ., 1998 U.S. Dist. LEXIS 407 (1998), Sotomayor quoted Kracunas v. Iona College, 119 F.3d 80, 85 (2d Cir. 1997): "When a teacher sexually harasses a student, that teacher discriminates on the basis of sex in violation of Title IX."