Court’s holding in Sullivan to support the proposition that a statute prohibiting discrimination should be construed to confer an “[i]mplicit ... cause of action protecting people from private retaliation for refusing to violate other people’s rights under § 1981 or for exercising their own § 1981 rights.” Fair Employment Council v. BMC Mktg. Corp., 28 F.3d 1268, 1280 (D.C.Cir.1994) (discussing 42 U.S.C. § 1981, which broadly prohibits discrimination in contracting). However, interpreting the Supreme Court’s recent decision in Alexander v. Sandoval, 532 U.S. 275, 121 S.Ct. 1511, 149 L.Ed.2d 517 (2001), other circuits have split on the question of whether a private cause of action for retaliation exists under Title VI and Title IX. Compare Peters v. Jenney, 327 F.3d 307 (4th Cir.2003) (<HOLDING>) with Jackson v. Birmingham Board of Educ., 309
holding that because the proper defendant in a title vi case is an entity rather than an individual plaintiff could not be sued in his individual capacity under title vi holding that a plaintiff can prove illegal retaliation under   1981 in the same manner as he establishes retaliation under title vii holding that a claim for retaliation does not lie under title ix recognizing that standards of liability under title vi are different from traditional agency principles or the general standards of liability under title vii holding that a plaintiff can sue for retaliation under title vi