# Alexander v. Sandoval *Case, United States Supreme Court, 532 U.S. 275 (2001), relevant to Minnesota through the Eighth Circuit's ruling in Female Athletes United v. Ellison* *Alexander v. Sandoval*, 532 U.S. 275 (2001), is a United States Supreme Court decision. It held that the private right of action under Title VI reaches intentional discrimination only.[^1] Under the decision, disparate-impact claims lie under the implementing regulations and are pursued through agency enforcement, not private suit.[^1] The case appears in the Minnesota record because the Eighth Circuit applied *Sandoval* in a 2026 opinion that arose under [[Title IX]] rather than Title VI.[^2] In *[[Female Athletes United v. Ellison]]*, No. 25-2899 (8th Cir., filed Apr. 15, 2026), the panel affirmed the district court's denial of a preliminary injunction.[^2] It applied *Sandoval* through *[[Cannon v. University of Chicago]]*, 441 U.S. 677 (1979), and held that Title IX supplies a private right of action only for intentional sex discrimination.[^2] ## Holding The Court held that Title VI's private right of action reaches intentional discrimination only.[^1] Disparate-impact claims lie under the implementing regulations, which are enforced by agencies.[^1] ## In the Minnesota record ### What - In *Female Athletes United v. Ellison*, the Eighth Circuit applied *Sandoval* through *Cannon* and held that Title IX supplies a private right of action only for intentional sex discrimination.[^2] - The panel held that the plaintiff's ineffective-accommodation and unequal-treatment claims "sound in disparate impact," for which there is no private right of action.[^2] At argument, Female Athletes United (FAU) conceded: "we don't contest that there is no disparate impact claim under Title IX."[^2] - The panel stated that executive guidance and agency findings "do not reflect settled law."[^2] It also stated that whether Title IX permits transgender participation "remains an open question of law," noting the pending *West Virginia v. B.P.J.*, No. 24-43, and *[[Little v. Hecox]]*, No. 24-38.[^2] ### Who - Judge Gruender wrote for a panel that included Judges Erickson and Grasz.[^2] - FAU's standing rested on a member identified as "Athlete 1," who faced a scheduled game against the transgender athlete.[^2] ### When - The Eighth Circuit's opinion in No. 25-2899 was filed April 15, 2026.[^2] ### Why - The panel held that FAU had standing. The claims failed on the scope of the private right of action.[^2] The source master records that this corrects an earlier characterization drawn from the Minnesota Attorney General's press release: the loss was on the private right of action, not on standing.[^2] The record does not establish any reason beyond the court's stated holding.[^2] ### Where - The case was decided by the United States Court of Appeals for the Eighth Circuit.[^2] ## Notes [^1]: Supreme Court of the United States, *Alexander v. Sandoval*, 532 U.S. 275 (2001) — Title VI's private right of action reaches intentional discrimination only; disparate-impact claims lie under the implementing regulations through agency enforcement. https://supreme.justia.com/cases/federal/us/532/275/ [^2]: *How Minnesota Got Here* (merged master, footnoted), note 43, summarizing the U.S. Court of Appeals for the Eighth Circuit, *Female Athletes United v. Ellison*, No. 25-2899 (opinion filed Apr. 15, 2026) — affirmance of the denial of a preliminary injunction; standing affirmed; Title IX private right of action limited to intentional discrimination under *Sandoval* and *Cannon*; FAU's concession at argument; correction of the Attorney General press-release characterization. The underlying source is the Eighth Circuit opinion, fetched verbatim; the pack has no URL for it.