In the 1983 case Grove City College et al. v. Bell, Secretary of Education, et al., the U.S Supreme Court ruled that Title IX, which prohibits sex discrimination in education programs receiving federal financial assistance, could be applied to a private school even if it did not directly receive federal funding but its students received federal grants. The Pennsylvania-based Grove City College argued that since they didn't directly receive any funds from the government and only their students did through Basic Educational Opportunity Grants (BEOGs), they should not have to comply with Title IX regulations. However, the court held in a 6-3 decision that because these student grants were given out by an institution participating in a federally funded program (the BEOG program), this constituted indirect receipt of federal aid by the college and thus made them subject to Title IX's anti-discrimination provisions.

In the dissenting opinion for Grove City College v. Bell, Justice Brennan, joined by Justices Marshall and Blackmun, argued that the majority's interpretation of Title IX was too narrow. They believed that if any part of an institution receives federal funding, then all parts should comply with anti-discrimination laws - not just the specific program or department receiving funds. The dissenters contended this broader interpretation better aligned with Congress' intent to eradicate sex discrimination in education when it enacted Title IX as a part of Education Amendments Act in 1972. They also pointed out that limiting application only to specific programs could allow institutions to continue discriminatory practices simply by shifting their funding around. In essence, they felt this ruling undermined efforts towards achieving gender equality in education.