Gratz v. Bollinger

539 U.S. 244 (2003)

Quick Summary

Jennifer Gratz and Patrick Hamacher (plaintiffs) challenged the University of Michigan’s admissions policy, which they claimed discriminated against them based on race, favoring underrepresented minority groups. Lee Bollinger, among other officials (defendants), defended the policy as promoting diversity.

The legal dispute centered on whether this policy violated constitutional protections against discrimination. The Supreme Court concluded that the policy was not narrowly tailored to serve a compelling interest in diversity and therefore was unconstitutional.

Facts of the Case

Jennifer Gratz and Patrick Hamacher (plaintiffs), both Caucasian individuals, sought admission to the University of Michigan’s College of Literature, Science, and the Arts (LSA) and were denied. They filed a lawsuit against Lee Bollinger and other university officials (defendants), challenging the University’s admissions policy.

The policy used a points system that automatically awarded twenty bonus points to applicants from underrepresented minority groups, which plaintiffs argued was discriminatory and violated the Equal Protection Clause of the Fourteenth Amendment.

The University defended its policy by asserting it promoted diversity within the student body, which they considered a compelling interest. The case ascended through the court system, raising questions about whether race could be a factor in university admissions and if the University’s policies were constitutionally permissible.

Procedural Posture and History

  1. Gratz and Hamacher filed a class-action suit in the United States District Court for the Eastern District of Michigan alleging racial discrimination in the University’s admissions policy.
  2. The District Court granted class certification and bifurcated the proceedings into liability and damages phases.
  3. The District Court ruled in favor of Gratz and Hamacher for admissions guidelines from 1995 to 1998 but upheld the University’s guidelines for 1999 and 2000.
  4. Both parties appealed, and the Sixth Circuit reviewed the case en banc alongside Grutter v. Bollinger.
  5. The Supreme Court granted certiorari before judgment from the Sixth Circuit.

I.R.A.C. Format

Issue

Whether the University of Michigan’s use of racial preferences in undergraduate admissions violates the Equal Protection Clause of the Fourteenth Amendment, Title VI of the Civil Rights Act of 1964, or 42 U.S.C. § 1981.

Rule of Law

The consideration of race in admissions decisions must meet the standards of strict scrutiny to ensure that it serves a compelling governmental interest and is narrowly tailored to achieve that interest without unduly harming members of any racial group.

Reasoning and Analysis

The majority opinion, delivered by Chief Justice Rehnquist, found that while diversity might constitute a compelling interest, the University’s point-based admissions policy was not narrowly tailored to achieve educational diversity. The automatic awarding of points based solely on race was akin to a quota system which is impermissible under the Equal Protection Clause.

The Court emphasized the need for individualized consideration of applicants rather than an automatic point allocation system.

Furthermore, the Court noted that previous admissions policies had effectively reserved spots for underrepresented minority applicants, which was also deemed unconstitutional. Such practices prevented non-minority applicants from competing for those admissions slots on an equal footing.

Conclusion

The Supreme Court reversed the portion of the District Court’s decision that upheld the University’s admissions guidelines, finding them to violate constitutional and statutory provisions by not being narrowly tailored to achieve a compelling interest in diversity.

Key Takeaways

  1. The use of racial quotas or points systems that automatically confer benefits based on race in university admissions is unconstitutional under the Equal Protection Clause.
  2. Any consideration of race in admissions must be part of a narrowly tailored policy that serves a compelling interest, such as promoting diversity, and must allow for individualized consideration of applicants.
  3. This case reaffirms that while diversity may be a compelling interest for universities, the methods used to achieve it must withstand strict scrutiny.

Relevant FAQs of this case

What constitutes a compelling interest that justifies the use of race in decision-making?

A compelling interest must be a vitally important goal that cannot be achieved through any other less discriminatory means. In the context of admissions, promoting diversity can be considered a compelling interest because it enriches the educational experience for all students and prepares them to function in a diverse society.

  • For example: A medical school aims to train doctors who can serve in underserved communities. It may consider the racial and socioeconomic backgrounds of applicants to fulfill this mission, as long as the policy is narrowly tailored to achieve that end and does not exclude other qualified applicants.

How does strict scrutiny evaluate policies that classify individuals based on race?

Strict scrutiny requires that a racial classification must serve a compelling state interest and must be narrowly tailored to achieve that interest. The government must also show there are no viable non-discriminatory alternatives that would achieve this interest to the same extent.

  • For example: If a city’s fire department implements an affirmative action plan due to a history of discrimination, the plan will be assessed to ensure it precisely addresses past disparities without imposing substantial harm on non-minority candidates.

When can individualized consideration override a generally applied policy?

Individualized consideration can override a generally applied policy when it involves constitutionally protected interests such as equality under the law. This ensures that each person is evaluated as an individual rather than just as a member of a group, preventing mechanical decisions based solely on race or another general characteristic.

  • For example: In employment, rather than applying blanket policies regarding conviction records, employers may need to consider each applicant’s specific situation if those blanket policies disproportionately affect certain racial groups.

References

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