This article will apply the Chester three-factor test to find a private right of action implied in the administrative regulations promulgated by various agencies to implement Section 602 of Title VI. This article also proposes that it would be inconsistent to apply today's more stringent standard for inferring congressional intent in deciding whether a private right exists under Section 602. Such inconsistency arises as a result of the Supreme Court's application of a more lenient standard in recognizing a private right of action under Section 601.
Mank, Bradford, "Is There a Private Cause of Action Under EPA's Title VI Regulations?: The Need to Empower Environmental Justice Plaintiffs" (1999). Faculty Articles and Other Publications. 255.