Congress passed Title IX of the 1972 Education Amendments (“Title IX” or  “the Act”) to end sex-based discrimination in education. Title IX states “[no]  person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance . . . .” The Act is most widely known for its application to sports, specifically in expanding opportunities for female athletes. While the Act never explicitly addresses athletics, prior to the passage of the Act, athletics were recognized as a  part of the educational process and subject to the Equal Protection Clause of the  Fourteenth Amendment.3 Not only does Title IX apply to athletics issues, but it also applies in situations involving sexual harassment and employment discrimination.