603 U.S. 866
SCOTUS2024Background
- The Department of Education issued a new rule redefining "sex discrimination" under Title IX to include sex stereotypes, sex characteristics, pregnancy or related conditions, sexual orientation, and gender identity.
- Multiple states challenged the rule, arguing it exceeded the statutory authority of Title IX and imposed unlawful definitions.
- District courts in Louisiana and Kentucky granted preliminary injunctions blocking enforcement of the whole rule in the plaintiff states.
- Appellate courts (Fifth and Sixth Circuits) refused to stay the injunctions during the pending government appeals.
- The federal government filed emergency applications in the Supreme Court seeking partial stays, aiming to keep unchallenged provisions in effect while appeals proceed.
- The Supreme Court denied the applications for stays, leaving the broad injunctions in place pending appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the new Title IX rule unlawfully redefines sex discrim. | Redefines sex discrimination beyond Congress's intent | Consistent with antidiscrimination goals of Title IX | Plaintiffs entitled to relief re: redefinition provisions |
| Whether the injunction should bar the entire rule | All provisions are intertwined with unlawful definitions | Only three challenged provisions harm plaintiffs | Injunction overbroad but left in place |
| Whether the three challenged provisions are severable | Definitions permeate the entire rule; not manageable otherwise | Unchallenged provisions are independent and should stand | Severability not established sufficiently by government |
| Whether enforcing the whole rule causes irreparable harm | Required compliance with unlawful provisions and state conflict | Harm only exists in challenged, not all, provisions | Only challenged provisions cause alleged injury |
Key Cases Cited
- Califano v. Yamasaki, 442 U.S. 682 (1979) (equitable relief should not be more burdensome than necessary to redress plaintiffs’ injuries)
- Madsen v. Women’s Health Center, Inc., 512 U.S. 753 (1994) (injunctions should not be broader than necessary to achieve remedial goals)
- Davis v. Monroe County Bd. of Ed., 526 U.S. 629 (1999) (standard for actionable sex-based harassment under Title IX)
- Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) (standard for preliminary injunctions—clear showing required)