The history of health care discrimination as well as ongoing, extensive evidence of racial disparities argue for continued vigilance in the area of health care and civil rights. Under Title VI of the Civil Rights Act of 1964, individuals have challenged de facto discriminatory policies adopted by health entities receiving federal financial assistance. Title VI health litigation is difficult because of complex issues of proof as well as confounding problems of poverty and lack of health insurance that affect both claims and remedies. An analysis of cases brought under the law suggests that discrimination claims within a particular market fare better than those challenging decisions to relocate or alter the market served. This has important implications for claims involving discrimination by managed care organizations. Because the same potential for discrimination exists in the new health system of managed care, although in altered form, data collection and evaluation are warranted.