In the case of National Collegiate Athletic Association v. R.M. Smith, the Supreme Court ruled in favor of the NCAA, stating that it was not an employer under Title IX and therefore could not be sued for employment discrimination. The plaintiff, Renee M. Smith, a former volleyball coach at St. Bonaventure University had filed a lawsuit against NCAA alleging gender discrimination after her application to participate in a coaching internship program was rejected by them twice consecutively due to their policy which required coaches' applications to be submitted through their university's athletic director - something she claimed her male counterparts were exempted from doing so informally or formally. The court held that while Title IX does apply broadly across educational institutions receiving federal funding (including athletics), it does not extend its reach into organizations like NCAA as they do not have traditional employer-employee relationships with coaches or athletes participating in intercollegiate sports programs.

The dissenting opinion in the case of NATIONAL COLLEGIATE ATHLETIC ASSOCIATION v. R. M. SMITH argued that the majority's decision to allow a private organization, such as NCAA, to be sued under Title IX was incorrect and could have far-reaching implications beyond this particular case. The dissenters believed that Congress did not intend for Title IX to apply to private organizations like the NCAA when it passed the law prohibiting sex discrimination in education programs receiving federal financial assistance. They also expressed concerns about how this ruling might affect other similar cases involving non-educational entities or those indirectly linked with educational institutions through funding or other relationships but are not directly involved in providing education services themselves.