The plaintiff, a female student, alleged she was sexually harassed by a teacher in the Gwinnett County Public School system. She argued that the school district's response was inadequate and violated Title IX. While the Court acknowledged the severity of the harassment and the school's failings, it ruled that Title IX's remedial scheme focused on equitable relief (such as injunctive relief to prevent future discrimination) and did not explicitly authorize monetary damages in private lawsuits. The Court reasoned that the statute's focus was on compliance with federal funding requirements, not the creation of a new tort (a civil wrong).
This decision has been highly controversial. Critics argue that it leaves victims of sexual harassment with limited recourse and makes it harder to hold schools accountable. Subsequent legislation and court interpretations have attempted to address some of the concerns raised by *Franklin*, but the core holding—that Title IX does not provide for private damages actions for sexual harassment *unless* the harassment is sufficiently severe to create a hostile environment that effectively denies educational opportunities—remains. The "hostile environment" requirement adds an important layer of scrutiny that wasn't present in the original decision. The ruling continues to shape the legal landscape surrounding sexual harassment in schools and the interpretation of implied private rights of action under federal statutes.