Case Particulars

Tribunal

Department of Education, Office for Civil Rights

Date Filed

May 8, 2025

Docket No.

OCR Case Number 04-25-2381

Case Status

OCR Complaint Filed

Case Overview

On May 8, 2025, the Equal Protection Project (EPP) filed a Civil Rights Complaint with the U.S. Department of Education’s Office for Civil Rights (OCR) against Middle Tennessee State University (MTSU) for “offering, administering, and promoting seventeen (17) scholarships that discriminate based on race, color, and/or national origin.”

The Complaint continues:

The scholarships listed below are currently offered to MTSU students and applicants for admission, according to the MTSU website, and violate Title VI of the Civil Rights Act of 1964 (“Title VI”) and its implementing regulations by discriminating against students based on their race, color, and/or national origin. Because MTSU is a public university, these discriminatory scholarships also violate the Equal Protection Clause of the Fourteenth Amendment of the U.S. Constitution.

The Complaint then uses MTSU’s own website to demonstrate the discriminatory nature of each of the 17 challenged scholarships.

Next, the Complaint explains why the challenged scholarships violate federal law and the United States Constitution:

Title VI of the Civil Rights Act prohibits intentional discrimination on the basis of race, color or national origin in any “program or activity” that receives federal financial assistance. See 42 U.S.C. § 2000d. The term “program or activity” means “all of the operations … of a college, university, or other postsecondary institution, or a public system of higher education.” See 42 U.S.C. § 2000d-4a(2)(A); Rowles v. Curators of the Univ. of Mo., 983 F.3d 345, 355 (8th Cir. 2020) (“Title VI prohibits discrimination on the basis of race in federally funded programs,” and thus applies to universities receiving federal financial assistance). As MTSU receives federal funds, it is subject to Title VI…

 

As MTSU is a public university, its offering, promoting, and administrating these discriminatory scholarships also violates the Equal Protection Clause of the Fourteenth Amendment.

Finally, the Complaint requests that OCR take action:

The Office for Civil Rights has the power and obligation to investigate MTSU’s role in creating, funding, promoting and administering these scholarships – and, given how many there are, to discern whether MTSU is engaging in such discrimination in its other activities – and to impose whatever remedial relief is necessary to hold it accountable for that unlawful conduct. This includes, if necessary, imposing fines, initiating administrative proceedings to suspend or terminate federal financial assistance and referring the case to the Department of Justice for judicial proceedings to enforce the rights of the United States under federal law.

 

Accordingly, we respectfully ask that the Department of Education’s Office for Civil Rights promptly open a formal investigation, impose such remedial relief as the law permits for the benefit of those who have been illegally excluded from MTSU’s various scholarships based on discriminatory criteria, and ensure that all ongoing and future scholarships and programming at MTSU comport with the Constitution and federal civil rights laws.

OCR is evaluating EPP’s Civil Rights Complaint for further action.