The Iron Arrow Honor Society v. Heckler case in 1983 involved the University of Miami's all-male honor society, Iron Arrow, and Margaret Heckler, then Secretary of Health and Human Services. The issue at hand was whether or not federal funds could be used by institutions that supported discriminatory organizations such as the Iron Arrow Honor Society which did not admit women. The Supreme Court upheld a lower court ruling stating that the university would lose its federal funding if it continued to recognize and provide facilities for this group due to violation of Title IX regulations prohibiting sex discrimination in education programs receiving Federal financial assistance. This decision led to significant changes within many universities across America who had similar societies operating on their campuses.

In the dissenting opinion for Iron Arrow Honor Society v. Heckler, Justice White argued that the majority had misinterpreted Title IX of the Education Amendments Act of 1972. He contended that this law was intended to prevent discrimination based on sex in educational programs or activities receiving federal financial assistance but did not intend to regulate membership policies of student organizations such as fraternities and sororities, let alone honor societies like Iron Arrow. The justice believed that Congress never meant for Title IX to apply so broadly and thus disagreed with its application in this case where a male-only honor society was barred from using University facilities due to non-compliance with anti-discrimination laws. He also expressed concern about potential far-reaching implications if all single-sex organizations were deemed discriminatory under these regulations.