The Supreme Court used the four-part "Cort v. Ash" test for several years, and in applying the test, "or the most part, the Court refused to create causes of action." An important application of the test, however, came in "Cannon v. University of Chicago" (1979), which recognized an implied private right of action. There, a plaintiff sued under Title IX of the Education Amendments of 1972, which prohibited sex discrimination in any federally funded program. The Court, stating that the female plaintiff was within the class protected by the statute, that Congress had intended to create a private right of action to enforce the law, that such a right of action was consistent with the remedial purpose Congress had in mind, and that discrimination was a matter of traditionally federal and not state concern. Justice Powell, however, dissented and criticized the Court's approach to implied rights of action, which he said was incompatible with the doctrine of separation of powers. It was the job of Congress, not the federal courts, Justice Powell said, to create causes of action. Therefore, the only appropriate analysis was whether Congress intended to create a private right of action. "Absent the most compelling evidence of affirmative congressional intent, a federal court should not infer a private cause of action."