U.S. Court of Appeals for the Sixth Circuit

Mark Charlton-Perkins v. Univ. of Cincinnati

August 5, 2026

Summary

The court affirmed summary judgment for the University and its administrators. It held that Title IX's protection for a “person in the United States” is geographically limited and does not cover a United States citizen residing abroad when the alleged discrimination occurred. It also held that sovereign immunity barred the official-capacity claims seeking instatement and that qualified immunity barred the individual-capacity damages claims because the asserted right was not clearly established.