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===Further legislation=== [[File:Patsy Mink 1994 portrait (cropped).tif|thumb|Representative [[Patsy Mink]] of Hawaii, Title IX co-author, for whom the law was renamed in 2002]] The Civil Rights Restoration Act of 1988 is tied to Title IX which was passed in response to the U.S. Supreme Court's 1984 ruling ''[[Grove City College v. Bell]].''<ref name="oyez">[http://oyez.org/cases/1980-1989/1983/1983_82_792 "The Oyez Project, Grove City College v. Bell"] {{webarchive|url=https://web.archive.org/web/20150905170922/http://www.oyez.org/cases/1980-1989/1983/1983_82_792 |date=September 5, 2015 }}, 465 U.S. 555 (1984)</ref> The Court held that Title IX applied only to those programs receiving direct federal aid.<ref name="EB">[http://www.britannica.com/EBchecked/topic/597287/Title-IX "Title IX."] {{webarchive|url=https://web.archive.org/web/20150604031040/http://www.britannica.com/EBchecked/topic/597287/Title-IX |date=June 4, 2015 }} ''Encyclopædia Britannica''. 2009. Encyclopædia Britannica Online. November 19, 2009</ref> This case was initially reached by the Supreme Court when [[Grove City College]] disagreed with the Department of Education's assertion that it was required to comply with Title IX. Grove City College was not a federally funded institution; however, they did accept students who were receiving [[Basic Educational Opportunity Grant]]s through a Department of Education program.<ref name="oyez"/> The Department of Education's stance was that because some of its students were receiving federal grants, the school was thus receiving federal assistance and Title IX applied to it. The Court decided that since Grove City College was only receiving federal funding through the grant program that only this program had to comply. This ruling was a major victory for those opposed to Title IX as it then made many athletic programs outside the purview of Title IX, and thus reduced its scope.<ref name="Suggs"/> Grove City's court victory, however, was short-lived. The Civil Rights Restoration Act passed in 1988, which extended Title IX coverage to all programs of any educational institution that receives ''any'' federal assistance, both direct and indirect.<ref name="now" /> In 1994, the Equity in Athletics Disclosure Act, sponsored by Congresswoman [[Cardiss Collins]] required that federally-assisted educational institutions disclose information on roster sizes for men's and women's athletic teams; as well as budgets for recruiting, scholarships, coaches' salaries, and other expenses, annually.<ref name="cases" /> In 1992, the Supreme Court decided monetary relief was available under Title IX in the case [[Franklin v. Gwinnett County Public Schools]].<ref>{{Cite web|url=https://www.oyez.org/cases/1991/90-918|title=Franklin v. Gwinnett County Public Schools|website=Oyez|language=en|access-date=December 9, 2019}}</ref> In October 2002, less than a month after the death of U.S. Rep. Patsy Mink, the U.S. Congress passed a resolution to rename Title IX the "Patsy Takemoto Mink Equal Opportunity in Education Act", which President George W. Bush signed into law.<ref>{{cite news|title=Bush signs resolution honoring Patsy Mink|url=http://the.honoluluadvertiser.com/article/2002/Oct/31/ln/ln41a.html|access-date=May 20, 2013|newspaper=Honolulu Advertiser|date=October 31, 2002|url-status=live|archive-url=https://web.archive.org/web/20131018064617/http://the.honoluluadvertiser.com/article/2002/Oct/31/ln/ln41a.html|archive-date=October 18, 2013}}</ref> On November 24, 2006, Title IX regulations were amended to provide greater flexibility in the operation of single-sex classes or extracurricular activities at the primary or secondary school level; this was largely to introduce federal abstinence-only programs, which may have been a partial basis for the support of President Bush.<ref>{{cite journal |url=http://www.ed.gov/legislation/FedRegister/finrule/2006-4/102506a.html |title=Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance |journal=Federal Register |volume=71 |number=206 |date=October 25, 2006 |access-date=June 24, 2012 |url-status=dead |archive-url=https://web.archive.org/web/20120620084108/http://www2.ed.gov/legislation/FedRegister/finrule/2006-4/102506a.html |archive-date=June 20, 2012 }}</ref> On May 15, 2020, the Department of Education issued a letter stating that the policy of the state of [[Connecticut]] which allows transgender girls to compete in high school sports as girls was a violation of the civil rights of female student-athletes and a violation of Title IX.{{Clarify|reason=This paragraph contradicts itself. Were trans girls allowed to participate as girls or not?|date=May 2025}} It stated that Connecticut's policy "denied female student-athletes athletic benefits and opportunities, including advancing to the finals in events, higher-level competitions, awards, medals, recognition, and the possibility of greater visibility to colleges and other benefits."<ref>{{cite news |title=Policy allowing transgender athletes to compete as girls found to violate US law |url=https://www.theguardian.com/sport/2020/may/28/connecticut-transgender-federal-civil-rights-lawsuit |access-date=June 8, 2020 |work=The Guardian |agency=Associated Press |date=May 28, 2020}}</ref> On March 8, 2021, President [[Joe Biden]] issued Executive Order 14021 entitled "Guaranteeing an Educational Environment Free From Discrimination on the Basis of Sex, Including Sexual Orientation or Gender Identity", reversing changes made by the [[First presidency of Donald Trump|first Trump administration]] to limit the scope of Title IX to sex only, excluding gender identity and sexual orientation. The executive order also provided a timeline for the [[United States Secretary of Education|Secretary of Education]] and [[United States Attorney General|Attorney General]] to "review all existing regulations, orders, guidance documents, policies, and any other similar agency actions (collectively, agency actions) that are or may be inconsistent with the policy set forth" in the order.<ref>{{Cite web |date=2021-03-08 |title=Executive Order on Guaranteeing an Educational Environment Free from Discrimination on the Basis of Sex, Including Sexual Orientation or Gender Identity |url=https://bidenwhitehouse.archives.gov/briefing-room/presidential-actions/2021/03/08/executive-order-on-guaranteeing-an-educational-environment-free-from-discrimination-on-the-basis-of-sex-including-sexual-orientation-or-gender-identity/ |access-date=2022-04-20 |website=The White House |language=en-US|archive-url=https://web.archive.org/web/20220413045208/https://www.whitehouse.gov/briefing-room/presidential-actions/2021/03/08/executive-order-on-guaranteeing-an-educational-environment-free-from-discrimination-on-the-basis-of-sex-including-sexual-orientation-or-gender-identity/|archive-date=April 13, 2022|url-status=live}}</ref> On June 16, 2021, the U.S. Department of Education's [[Office for Civil Rights]] issued a Notice of Interpretation explaining that it will "enforce Title IX's prohibition on discrimination on the basis of sex to include: (1) discrimination based on sexual orientation; and (2) discrimination based on gender identity."<ref>{{Cite web |title=U.S. Department of Education Confirms Title IX Protects Students from Discrimination Based on Sexual Orientation and Gender Identity {{!}} U.S. Department of Education |url=https://www.ed.gov/news/press-releases/us-department-education-confirms-title-ix-protects-students-discrimination-based-sexual-orientation-and-gender-identity |access-date=2022-04-20 |website=www.ed.gov|date=June 16, 2021|archive-url=https://web.archive.org/web/20220413095512/https://www.ed.gov/news/press-releases/us-department-education-confirms-title-ix-protects-students-discrimination-based-sexual-orientation-and-gender-identity|archive-date=April 13, 2022|url-status=live}}</ref><ref>{{Cite web|url=https://www2.ed.gov/about/offices/list/ocr/docs/202106-titleix-noi.pdf|title=Federal Register Notice of Interpretation: Enforcement of Title IX of the Education Amendments of 1972 with Respect to Discrimination Based on Sexual Orientation and Gender Identity in Light of Bostock v. Clayton County|website=www2.ed.gov|publisher=[[United States Department of Education]]|access-date=April 20, 2022|archive-url=https://web.archive.org/web/20220406135319/https://www2.ed.gov/about/offices/list/ocr/docs/202106-titleix-noi.pdf|archive-date=April 6, 2022|url-status=live}}</ref> The review set out in Executive Order 14021 is still ongoing as of April 2022.
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