The landmark event to which all federal laws and court decisions affecting civil rights in public education must be related is the 1954 Supreme Court decision in the Brown v. Board of Education case. In that case, the court applied the equal protection clause of the Constitution to ban racial discrimination in schools. The idea of equal protection went beyond racial desegregation and was expressed in laws requiring nondiscriminatory treatment of women, handicapped persons, and older adults. Beginning with the Civil Rights Act of 1964, federal laws prohibited racial, sex, handicap, and age discrimination. The legislation dealing most directly with sex discrimination in schools was Title IX of the Education Amendments of 1972. The Supreme Court decision, Grove City College v. Bell (1984), held that the proper reading of Title IX indicated that only the particular program of an educational institution receiving federal funds needed to comply with the fundor guidelines related to Title IX's prohibition of sex discrimination. The practice of requiring only the program and not the institution as a whole to obey the antidiscrimination guidelines specified by funding agencies can be described by the following two examples. In the first example, a summer school program received federal funds and a program operated during the regular academic year did not. Citing the very narrow definition of the term recipient of federal financial assistance used in the Grove City case, a judge could rule that only the summer program was under an obligation to obey federal antidiscrimination laws. Applying such logic, the penalty for noncompliance would be the cutoff only of those funds going to the summer school program. Other federal funds would not be endangered by the failure of the summer