In the 1981 case North Haven Board of Education et al. v. Bell, Secretary of Education, et al., the U.S Supreme Court ruled that Title IX, which prohibits sex discrimination in any education program or activity receiving federal financial assistance, applies to employment practices at educational institutions as well. The case arose when two Connecticut school boards challenged the Department of Health and Human Services' regulations extending Title IX's reach to employment issues on grounds that Congress had not intended such an application when it enacted Title IX. However, by a vote of 6-3, the court held that given its broad language and purpose - ending sex discrimination in schools - there was no reason why Congress would have wanted to limit its scope only to students and not protect teachers or other employees from gender-based discriminatory practices.

In the dissenting opinion of North Haven Board of Education v. Bell, Justice Powell argued that Title IX should not be applied to employment practices in educational institutions. He believed that Congress intended for Title IX to focus on ending discrimination against students rather than employees. The majority's interpretation, according to him, extended beyond what was originally intended by the law and could potentially lead to a floodgate of litigation over various employment issues unrelated to sex discrimination in education programs or activities. Furthermore, he expressed concern about federal agencies' broad authority under this interpretation and warned it might undermine local control over schools.