Supreme Court Case

On February 28th, 1984, the Supreme Court ruled in favor of Bell, who represented the U.S. Department of Health, Education, and Welfare, in the case, Grove City College vs. Bell.

In 1976, as part of the recently passed Title IX of the Education Amendments of 1972, Grove City College was sent an “Assurance of Compliance” which required a pledge of non-discrimination on the basis of gender. However, the document also required that the college comply with all federal regulations both present and future.

Grove City College, as a private institution which had never received direct federal funding and deeply valued independence, did not want to sign what they viewed as a “blank check” to the federal government, despite agreeing with the intentions of Title IX. The President of the college, Charles S. MacKenzie, refused to sign, which lead to the eventual termination of several Grove City College students’ federal financial aid.

In 1978, the College filed a lawsuit to the United States District Court for the Western District of Pennsylvania to force the Department to return the money to the students and to make the Department not require the Assurance of Compliance. This marked the beginning of a legal battle between Grove City College and the federal government’s Department of Health, Education, and Welfare. Representing the U.S. government was Terrel H. Bell, the acting United States Secretary of Education. The District court ruled on the side of the College that the Department could not terminate student funds simply because the College would not sign the Assurance of Compliance. Neither side was completely satisfied, so both parties appealed to the U.S. Court of Appeals Third Circuit, which in a ruling more in favor of Bell than the District court’s ruling was. Even more unhappy with this decision, Grove City College took the case to the Supreme Court.

On November 29th, 1983, the Burger Court first heard Grove City College vs. Bell. As the College had been found in the District court’s ruling as having not “discriminated on the basis of gender,” the case argued for the principle of government independence, not the actual discrimination which Title IX was written to address.

After about three months, Justice White presented the majority opinion. The Court ruled that when only specific programs benefitted from federal grants, Title IX did not hold sway over the whole college. The Court upheld the termination of student grants because they used the money to pay tuition to Grove City College. That said, the Court also ruled that the U.S. government could only demand an official Assurance of Compliance from the financial aid program as the federal grants given only aided that specific program.

The ruling on Grove City v. Bell lead to Grove City College no longer accepting any form of federal financial aid for students. Instead, Grove City College uses their own form and collects their own data from students to provide privately raised funding to meet financial need.

The ruling in this case was swiftly overturned three years later with the Civil Rights Restoration Act of 1987, which explicitly required compliance with all civil rights laws from all recipients of federal money. However, Grove City College was not affected as they had already decided to stop receiving any federal aid, including financial aid to students.

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