The Supreme Court of the United States held that Title IX does encompass a private cause of action for retaliation as an act of intentional discrimination, even when the plaintiff was not subjected to the original discriminatory treatment.
Jackson v. Birmingham Board of Education, 544 U.S. 167 (2005).
Sarah M. Riley,
Title IX Prohibits Retaliation against Plaintiff Who Complains of Sex Discrimination, Even If Plaintiff Is Not Recipient of Original Discriminatory Treatment: Jackson v. Birmingham Board of Education,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol44/iss4/7