decisions 7 signaled a "monumental change" 8 in the interpretation of Title IX that put the varsity athletics programs of virtually every college and university in violation of the law. These three decisions interpreted Title IX to require that colleges and universities provide varsity positions for male and female athletes in proportion to the enrollment of male and female students in the overall student body. Women currently comprise about 50% of college students and 36% of college varsity athletes. 9
             In this era of tight budgets, achieving a varsity participation ratio that is proportionate to enrollment would require most institutions to eliminate men's teams and to create women's teams. Male athletes affected by such cutbacks have objected that a proportionality requirement would transform Title IX from a statute that forbids discrimination to a statute that requires it. Male athletes have argued that allocating 50% of college varsity slots to women and the other 50% to male athletes is blatant sex discrimination
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