thletic departments falling under the auspices of Title IX, as few of them received any direct financial aid. [5]In contrast, those supporting the institution-wide viewpoint argued that an entire educational institution falls under the requirements of Title IX if any part of the institution was the recipient of federal monies. Because almost every American institution of higher education receive some type of federal aid or admits students who receive federal loans, this interpretation brought almost all interscholastic and collegiate athletic departments within Title IX's grasp.Advocates of both perspectives asserted that Title IX's limited legislative history supported their view. Institution-wide proponents also argued that direct financial funding intrinsically had no bearing on whether programs were benefiting from federal money. Specifically, they used a “release theory”, finding that when the federal government aids one program in an institution, that program is able to “release” money to other programs in the institution. In essence, this “other”, indirectly funded program (such as an athletic department) was still benefiting from federal resources. As a result, the first major court case to try Title IX was Grove City v. Bell, 465 U.S. 455 (1984). In this case, the Supreme Court ruled to remove the applicability of Title IX in athletics programs by ruling that the only programs which must comply with Title IX are those programs which are directly receiving Federal financial assistance. [6] On March 22, 1988, Grove City V. Bell was overruled when Congress overrode a Presidential Veto, by Ronald Reagan, to enact the Civil Rights Restoration Act Of 1987. This act made it law that any educational institution which receives any Federal aid be bound by Title IX in its entirety, not just those programs receiving the aid. This act, under (2)(A), meant a “college, university, or other postse...
