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In Brown v. Board of Education, Chief Justice Warren stated unequivocally that, "[I]n the field of public education the doctrine of 'separate but equal' has no place. Separate educational facilities are inherently unequal. '1 The backdrop for Brown was, of course, discrimination by race, and until recently no court had seriously questioned the constitutionality of public schools segregated on the basis of sex. 2 However, both the evolving standard of equal protection 3 as applied to discrimination by sex and the Equal Educational Opportunities Act of 19744 raise difficult questions as to the continued validity of single-sex public schools. In this Note, these constitutional questions will be discussed in light of the standards of equal protection enunciated since Reed v. Reed. 5 The focus of this analysis will be on the place, if any, of the doctrine of "separate but equal" in the area of discrimination by sex. Finally, the applicability and significance of the Equal Educational Opportunities Act to single-sex public schools will be examined, with emphasis on its perplexing legislative history. Historically, single-sex primary and secondary schools have been a rarity in American public education.6 From their inception, American public schools were generally open to both sexes. In the smaller settlements, of course, coeducation was mandated by considerations of economy and convenience; but even in the more densely populated eastern cities where single-sex schools posed no such financial or logistical problems, there was little demand for segregation by sex, and coeducation was the norm. One English commentator, in contrasting the American preference for coeducation with Britain's long history of single-sex schools, theorized that the mixed school was "the embodiment of the American doctrine of equal educational opportunities for all." 7 The relatively few single-sex public

Single-Sex Public Schools: The Last Bastion of "Separate but Equal"?