In the case of "Reed v. Reed," the Supreme Court held in 1971 that discrimination between classifications of people by state agencies was unacceptable unless there is some "fair and substantial relation" between the state actions in question and the classification being made, guaranteeing "that all persons similarly circumstanced shall be treated alike." In the case of athletics, the physical differences between men and women may affect whether they are considered "similarly circumstanced." Cases involving sex discrimination in athletics are primarily of three types: those in which women are denied athletic opportunities; those in which distinctions are made between contact and non-contact sports; and those dealing with the equality of separate programs. Different courts have reached different conclusions in cases of each of these three types. It may be more advisable for colleges and school districts to try to follow the regulations governing equal opportunity developed from Title IX of the Education Amendments of 1972 (discussed at some length in this article) than to second guess the local courts, particularly since decisions concerning what is "equal" depend on context and will have to be made on a case-by-case basis. (Author/PGD)