Dr. Lesley Williams v. Board of Regents of the University System of Georgia, et al
Split Score
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Case Summary
Disposition
Affirmed
A former anesthesiology resident sued Augusta University and the Georgia Board of Regents for sex and disability discrimination, retaliation, due-process violations, and breach of contract after she was dismissed from the residency. The Eleventh Circuit upheld the district court’s grant of summary judgment for the defendants on every claim, finding insufficient evidence of discrimination or retaliation, no ADA/Rehabilitation Act violation, adequate procedural protections, and no contract breach.
Circuit Split Identified
Legal Issue
Whether Title IX provides an implied private cause of action for employees of federally funded educational institutions to sue for sex-based employment discrimination (i.e., whether Title VII is the exclusive federal remedy for such claims).
Circuit Positions
Title IX DOES provide a private right of action to employees for sex-based employment discrimination.
Title IX does NOT provide a private employment-discrimination cause of action; employees must sue under Title VII.
Conflict Summary
Several circuits permit employees of educational institutions to pursue sex-discrimination claims directly under Title IX, reasoning that the statute’s broad language covers ‘any person’ and that Title VII does not foreclose parallel remedies. Other circuits, including the Eleventh, hold that Title IX’s implied right of action is limited to students and does not extend to employment, making Title VII the exclusive remedy for employees.