Part II of this Comment is a brief history of Title IX, from the enacting legislation through the 1980's. Part III summarizes recent decisions, identifying the issues courts are grappling with and what lines, if any, are being drawn. In Part IV, analyzes three issues which are repeatedly presented in recent cases. These issues are those upon which the courts have disagreed, or which pose potential problems in future litigation: 1) how should courts treat the tensions between the individual plaintiffs and the class-oriented goals of Title IX; 2) how much deference should school administrators be given when making budget decisions; and 3) is it appropriate to award monetary damages to successful plaintiffs? This Comment concludes that the long term goals of Title IX, as well as the overall success of college sports, are better served by .treating all claims as class actions, by giving administrators more deference than some courts have been willing to give, and by refusing to grant monetary damages. In essence, courts need to promote long term success rather than the short term goals of individuals.
Christopher Raymond, Title IX Litigation in the 1990's: The Courts Need a Game Plan, 18 SEATTLE U. L. REV. 665 (1995).