Jackson v. Birmingham Bd. of Ed., 544 U.S. 167 (2005)
Primary Holding
Title IX of the Education Amendments of 1972 encompasses claims of retaliation against individuals who complain about sex discrimination in educational programs, thereby allowing for a private right of action in such cases.
In the case of Jackson v. Birmingham Board of Education, a teacher named Roderick Jackson complained about unfair treatment of the girls' basketball team, and instead of fixing the issue, the school punished him by taking away his coaching position. The Supreme Court ruled that under Title IX, which protects against sex discrimination in education, people can sue if they face retaliation for reporting such discrimination. This decision helps protect consumers by ensuring that if someone speaks up about unfair treatment based on sex, they have the right to take legal action if they are punished for it, making it relevant for anyone facing similar situations in schools or educational programs.
AI-generated plain-language summary to help you understand this case
Roderick Jackson, a teacher and girls’ basketball coach in the Birmingham, Alabama public school system, alleged that the Birmingham Board of Education retaliated against him for complaining about sex discrimination in the athletic program. After discovering that the girls’ basketball team was not receiving equal funding, equipment, and access to facilities compared to the boys’ team, Jackson began voicing his concerns to his supervisors in December 2000. Despite his complaints, the Board did not address the issues, and instead, Jackson faced negative performance evaluations and was ultimately removed from his coaching position in May 2001, although he remained employed as a teacher without supplemental pay for coaching. Following his removal, Jackson filed a lawsuit in the United States District Court for the Northern District of Alabama, claiming that the Board's actions constituted retaliation in violation of Title IX of the Education Amendments of 1972. The Board moved to dismiss the case, arguing that Title IX did not provide a private right of action for retaliation. The District Court agreed and dismissed Jackson's complaint. Jackson then appealed to the Court of Appeals for the Eleventh Circuit, which affirmed the dismissal, reasoning that Title IX's text did not indicate any congressional intent to protect against retaliation for complaints regarding discrimination. The case ultimately reached the Supreme Court on a writ of certiorari, where the central issue was whether Title IX encompasses claims of retaliation against individuals who report sex discrimination. The Supreme Court was tasked with determining if the private right of action implied by Title IX included protections against retaliation for such complaints.
Whether Title IX of the Education Amendments of 1972 encompasses claims of retaliation against individuals who complain about sex discrimination in educational programs.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- November 30, 2004
- Jurisdiction
- federal
- Case Type
- landmark
- Damages Awarded
- N/A
- Data Quality
- high
Burlington Northern & Santa Fe Railway Co. v. White, 548 U.S. 53 (2006)
Consumer WonThe anti-retaliation provision of Title VII of the Civil Rights Act of 1964 protects employees from employer actions that would dissuade a reasonable worker from making or supporting a charge of discrimination, and it is not limited to actions that affect the terms and conditions of employment or occur at the workplace.
CBOCS West, Inc. v. Humphries, 553 U.S. 442 (2008)
Consumer WonSection 1981 of the Civil Rights Act encompasses claims of retaliation against individuals who have complained about violations of contract-related rights, affirming that such protections extend beyond direct discrimination to include retaliatory actions.
Smith v. City of Jackson, 544 U.S. 228 (2005)
Consumer LostThe Age Discrimination in Employment Act (ADEA) allows for recovery under a "disparate-impact" theory of discrimination, similar to that established in Griggs v. Duke Power Co., but the plaintiffs must still demonstrate a valid disparate-impact claim to succeed.
Arbaugh v. Y & H Corp., 546 U.S. 500 (2006)
Consumer WonThe numerical threshold of having "fifteen or more employees" in Title VII's definition of "employer" does not affect federal-court subject-matter jurisdiction but instead relates to the substantive adequacy of a Title VII claim for relief, and thus cannot be raised as a defense late in the litigation.