Mississippi University for Women v. Hogan

Instead Hogan filed an action in the U.S. District Court for the Northern District of Mississippi, asserting that the school's policy violated the Fourteenth Amendment, which declared that states cannot make or enforce a law that violates constitutional freedoms, because citizens are entitled to equal protection. His suit requested injunctive relief--a change in the Mississippi University's women-only admissions policy--as well as damages. The district court denied injunctive relief and supported the single-sex admission policy by applying the "minimal scrutiny" test. Up to this point in time, most discrimination cases were judged using minimal scrutiny, which declared a gender-specific statute to be valid if there was a rational correlation to a sensible legislative goal. In this case, the court conceded that providing women with the option of a female-only nursing education was a valid state objective and thus passed the minimal scrutiny gauge.