In Cannon v. University of Chicago, 441 U.S. 677, 99 S.Ct. 1946, 60 L.Ed.2d 560 (1979) the Supreme Court ruled that since Title IX of the Civil Rights Act was patterned after Title VI of that Act, and Title VI creates an implied private right of action for discrimination, Title IX should also be read to imply a private right of action. This reasoning applies with reference to 504 of the Rehabilitation Act, which was also patterned after Title VI of the Civil Rights Act. Section 601 of the Civil Rights Act of 1964, 42 U.S.C. 2000d, and Section 901(a) of Title IX of the Education Amendments of 1972, 901-903, are virtually the same as 504 of the Rehabilitation Act, 29 U.S.C. 794. Section 601 is framed the same way except that it refers to race, color or national origin. Section 901(a) has the same qualities, although it refers to discrimination based on sex as its object whereas in 504 the reference is to otherwise qualified handicapped individuals. In Cannon, the Supreme Court expressly rejected the court of appeals' reasoning that since 902 of Title IX established a procedure for the termination of federal financial support for institutions violating 901, that Congress intended that remedy to be the exclusive means of enforcing the statute. The Court recognized that Title IX and Title VI sought to accomplish two purposes: "to avoid the use of federal resources to support discriminatory practices," and "to provide individual citizens effective protection against those practices." 441 U.S. at 704, 99 S.Ct. at 1961. The Court held that a private right of action was necessary to promote the second of those purposes. For the same reasons, 504, expressly based on and modeled after Title VI of the Civil Rights Act and Title IX of the Education Amendment, must also be read to imply a private right of action if individual handicapped persons are to have effective protection against prohibited discriminatory practices. Moreover, the Court in Cannon rejected the defendant's argument that a private cause of action should not be implied when the result would be "to subject admissions decisions of universities to judicial scrutiny at the behest of disappointed applicants on a case by case basis." Id. at 709, 99 S.Ct. at 1964. In Cannon v. University of Chicago, 441 U.S. 677, 99 S.Ct. 1946, 60 L.Ed.2d 560 (1979), the Court framed the implied private right of action question as one of "statutory construction" in which the Court's task is to determine whether "Congress intended to make a remedy available." 441 U.S. at 688, 99 S.Ct. 1946. The Cannon Court nonetheless relied on the four Cort v. Ash factors because they were "indicative of such intent." Id. Thus, Congress's intent to create a private right of action-virtually ignored in Borak and described in Cort v. Ash merely as one of four factors - emerged as the primary factor in Cannon. The Court in Touche Ross & Co. v. Redington, 442 U.S. 560, 99 S.Ct. 2479, 61 L.Ed.2d 82 (1979), established that congressional intent is the exclusive factor, declaring that the task of courts is "limited solely to whether Congress intended to create the private right of action," 442 U.S. at 568, 99 S.Ct. 2479, and instructing that courts should use the Cort factors only to the extent that they help to determine legislative intent, id. at 575-76, 99 S.Ct. 2479.