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The Case of Park City University

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In the present case, Park City University has failed to show history and continuing practice of expanding opportunities for women athletes. Unlike Cohen, Part City University cannot establish that it has a great history of program expansion for the underrepresented sex. In Cohen, the court found that Brown had a history of expansion because it implemented 14 women’s programs between 1971 and 1977, followed by their last program expansion in 1982. In contrast, in the present case Park City University implemented just seven women’s teams between 1970 and 1990 followed by their last expansion in 2003. In comparison to Cohen, Park City University added just half number of teams in almost twenty years of the time period. Additionally, applying the court’s reasoning of Cohen in the present case, Park City University failed to continue to expand its program in response to the interests and abilities of women, since it did not make efforts to increase opportunity for women athletes for the time period of 22 years. If Park City University had added women's teams between 1990 and 2003, and then refused to establish women's golf team, the court would find Park City University in compliance with the continuing practice of program expansion requirement. Since, it is apparent that Park City University had failed to provide a history and continuing practice of program expansion for females, it did not satisfy the prong two tests under Title IX three-part test. On the other hand, in Ollier

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