Quick Summary
Barbara Grutter (plaintiff) sued Lee Bollinger and others (defendants) after being denied admission to the University of Michigan Law School, alleging racial discrimination in violation of the Constitution and federal law. The Law School admitted to using race as one of many factors in admissions to ensure diversity.
The central issue was whether this use of race was constitutional. The Supreme Court ultimately held that achieving a diverse student body is a compelling state interest and that the Law School’s admissions policy was appropriately narrow in its use of race as a factor.
Facts of the Case
Barbara Grutter (plaintiff), a white Michigan resident, applied to the University of Michigan Law School with impressive academic credentials—a 3.8 GPA and an LSAT score of 161. Despite her qualifications, Grutter’s application was rejected.
The Law School had an admissions policy that considered race as a significant factor to ensure a diverse student body, particularly including students from groups historically discriminated against, such as African-Americans, Hispanics, and Native Americans.
Grutter filed suit against Lee Bollinger, the university president, and other university officials (defendants), claiming the Law School’s admissions policy violated the Equal Protection Clause of the Fourteenth Amendment, Title VI of the Civil Rights Act of 1964, and 42 U.S.C. § 1981. She argued that her rejection was a product of unlawful racial discrimination.
Procedural Posture and History
- The District Court ruled in favor of Grutter, declaring the Law School’s use of race in admissions to be unlawful.
- The Court of Appeals for the Sixth Circuit reversed the District Court’s decision, leading Grutter to petition for certiorari to the Supreme Court.
I.R.A.C. Format
Issue
Whether the University of Michigan Law School’s consideration of race in its admissions decisions violates the Equal Protection Clause of the Fourteenth Amendment.
Rule of Law
The Equal Protection Clause prohibits any state from denying any person within its jurisdiction equal protection of the laws, which includes strict scrutiny of any racial classification imposed by the government.
Reasoning and Analysis
In its decision, the Supreme Court recognized that while all racial classifications are subject to strict scrutiny, such scrutiny does not automatically invalidate government use of race. The Court emphasized that context matters and that not all decisions influenced by race are equally objectionable.
The Court agreed with Justice Powell’s rationale in Bakke that diversity can be a compelling state interest justifying the use of race in university admissions if narrowly tailored.
The Supreme Court also noted that achieving a diverse student body serves a compelling state interest in providing an educational environment that fosters cross-cultural understanding and prepares students for a diverse workforce and society. The Law School’s policy was found to be narrowly tailored because it considered race as one factor among many in a holistic review process and did not employ quotas.
Conclusion
The Supreme Court upheld the University of Michigan Law School’s admissions policy, ruling that the narrowly tailored use of race in admissions decisions to achieve a diverse student body is lawful under the Equal Protection Clause.
Key Takeaways
- Diversity can constitute a compelling state interest justifying the consideration of race in university admissions.
- Race-based admissions policies must be narrowly tailored and cannot rely on quotas or set percentages.
- The Supreme Court reaffirmed the principle that strict scrutiny must be applied to all governmental use of racial classifications.
Relevant FAQs of this case
What criteria must a government race-based action meet to pass strict scrutiny?
To pass strict scrutiny, a government race-based action must demonstrate a compelling governmental interest and must be narrowly tailored to achieve that interest without unnecessary abridgments of constitutional rights. It is the most stringent form of judicial review.
- For example: If a city establishes a scholarship program to enhance opportunities for minority students, the program must clearly define its educational objectives and ensure it does not exclude eligible candidates solely on the basis of race more than is required to achieve its goals.
How can diversity be considered a compelling interest in academic institutions?
Diversity is considered a compelling interest because it enriches the educational experience by exposing students to a broad range of perspectives and backgrounds, aiding in the preparation for a diverse workforce and promoting social cohesion.
- For example: A business school might argue that the inclusion of students from various industries, cultures, and socioeconomic backgrounds will stimulate more insightful discussions and better prepare graduates for international commerce.
What differentiates a 'narrowly tailored' affirmative action program from one that is not constitutionally permissible?
A ‘narrowly tailored’ affirmative action program is designed to fit specific goals closely, such as educational diversity, without being overly broad or employing quotas. It uses race as one factor among others in holistic consideration rather than as a decisive or exclusive criterion.
- For example: A medical school’s admission policy that considers socioeconomic background, personal achievements, and race among other factors, aiming to build a diversified class without setting aside a certain number of seats for specific racial groups, would be narrowly tailored.
References
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