Grove City College v. Bell

Grove City College v. Bell: The Background

Grove City College is a private, co-educational liberal arts school. In the early 1980’s Grove City College sought to preserve its institutional autonomy by perpetually refusing state and federal assistance. Grove City College; however, did enroll a number of students receiving Basic Educational Opportunity Grants through a Department of Education-run program. As a result, the United States DOE concluded that assistance to students qualified the school as a recipient of federal assistance and made it subject to all nondiscrimination requirements of Title IX and other Acts of the Education Amendments of 1972.

When Grove City College refused to comply with the requirements, the DOE attempted to do away with assistance to the student financial aid program. In response, Grove City College challenged the DOE’s actions and attempted to maintain its independent status.

Title IX is a fundamental portion of the Education Amendments of 1972. The provision stated that no individual in the United States shall, on the basis of gender, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under education programs or activities receiving federal aid.

Grove City College v. Bell: The Question

The question of Grove City College v. Bell asked whether Grove City College was subject to federal requirements because its students received federal grants. Also, Grove City College v. Bell asked whether the provisions of Title IX violated the First Amendment rights of Grove City College.

Grove City College v. Bell: The Decision

In Grove City College v. Bell, the Supreme Court of the United States ruled against the college in a 7 to 2 vote. The Supreme Court of the United States held that there was no “substantive difference” between institutional assistance and aid received by schools through its students. The court in Grove City College v. Bell found that Title IX coverage was triggered by the Basic Educational Opportunity Grants.

The Supreme Court of the United States noted that the assistance offered by the grants did not trigger institutional coverage under the Amendments. That said, only Grove City College’s financial aid program was subject to the federal requirements. The court in Grove City College v. Bell concluded that prohibiting discrimination as a condition for federal assistance did not affect nor infringe upon the First Amendment rights of the College and the institution was fee to terminate its participation in the grant program.