Mississippi University For Women v. Hogan

458 U.S. 718 (1982)

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Nature of the Case

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Facts

Respondent Hogan (P), who is male, was denied admission to the nursing school at Mississippi University of Women, a state-operated facility, based on a Mississippi statute which restricts enrollment to females. P was allowed to audit classes but not to receive any credit. The University (D) contended that its admissions policy furthered its goal to increase female nurses. The Respondent sought injunctive relief. The District Court denied preliminary injunctive relief. The Court of Appeals reversed, holding that the District Court improperly used a 'rational relationship' test to judge the constitutionality of the policy. It held that the proper test is whether the State has carried the heavier burden of showing that the gender-based classification is substantially related to an important governmental objective. It then found that D had failed to show that providing a unique educational opportunity for females, but not for males, bears a substantial relationship to that interest. The court vacated the summary judgment entered against P as to his claim for monetary damages and remanded for entry of a declaratory judgment in conformity with its opinion. On rehearing, the Court of Appeals held that § 5 of the Fourteenth Amendment does not grant Congress power to authorize States to maintain practices otherwise violative of the Amendment.