 The Court rejected the argument, put forward both by Sandoval and by Justice Stevens's dissenting opinion, that because "Cannon" involved disparate impact, "Cannon" held that Title IX and, by extension Title VI, create a private right of action to enjoin policies that create a disparate impact.Both Sandoval and Justice Stevens relied on a footnote in "Cannon", which stated that the effect of the policies that the "Cannon" plaintiff challenged was "to exclude women from consideration.