Title IX of the Education Reformation Act was passed in 1972 for the purpose of providing equality between males and females in intercollegiate sports. Since its inception the disparity between men's and women's varsity athletics programs has persisted throughout American colleges and universities. Discrimination and equal protection concerns define the continuing debate of gender equality under the Act. Campuses across the Nation have seen athletic departments add women's varsity sport programs and cut men's programs in order to remain compliant under the Act. This paper explores the equal protection concerns of proportionality amongst enrollment rates and participation rates in intercollegiate athletics. The state of Title IX today remains clouded with questions by college administrators who, after over three decades of enforcement, are employing proportionality concepts as a measure to obtain gender equality in sports. The proportionality practice of cutting men's programs instead of adding women's programs may undermine the purpose of Title IX. This paper is an analysis of the Court decisions and lawsuits that characterize the controversy of Title IX and its legal application to claims of gender bias associated with female athletic programs. The study of this concern is imperative and will shape how college athletic programs are administered in the future. (Contains 22 footnotes.)