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The policy of Michigan University provided for a race as a consideration in admissions. This policy aimed at increasing diversity in the university. Ms. Barbara Grutter, a white Michigan resident with 161 LSAT and 3.8 grades, applied for admission to the university.
The university rejected her application because of her race. Ms. Grutter filed an action for discrimination on the grounds of race, contrary to Title VI of the Civil Rights Act of 1964 and the Fourteenth Amendment. The university argued that it did not apply a quota system but only pursued a critical mass of marginalized minority groups.
Was the use of a racially discriminatory program in the university admissions a violation of the constitutional safeguards against discrimination?
Holding of the opinion
The court held that the affirmative action initiative by Michigan University was constitutional. The majority opinion was that a state law school might use racial preference in student admissions because the diversity of the student body is a necessary state interest.
Thus, the court concluded that the admissions process by the school was adequately personalized and holistic to satisfy compelling state interest standards. Rehnquist CJ, Scalia J, Kennedy J, and Thomas J gave dissent opinion. Rehnquist and Kennedy argued that the use of race preference as a factor for school admission violated the Equal Protection Clause.
The court made its decision in line with Powell J’s concurrent opinion in Regents of the University of California v Bakke that permitted racial discrimination as a significant consideration for university admission but found quota systems to be unconstitutional. The reasoning behind the majority opinion was that a state law school carries out an extremely personalized review of all applicants. The reviews were constitutional because they operated in line with the objective of attaining the institutional benefits of diversity.
The admissions on racial grounds were not harmful to any racial group since all candidates had the chance to demonstrate how they would promote the diversity of the student body. Furthermore, the university never accepted or rejected any admission on automatic grounds of a variable such as racial preference. The admission process put into consideration all aspects that were likely to contribute to the diversity of the student body.
According to Chief Justice Rehnquist, it is constitutional to use racial preferences as an element for admission where it is narrowly personalized to satisfy compelling state interests. He, however, argued that the procedures of Michigan University were not narrow enough to achieve the objective of a diverse student body because they did not apply equally to all racial groups. Justice Kennedy added that the policy of the school on admissions failed to safeguard individualized assessment.
Future constitutional implications
The decision provided a constitutional basis for state universities and other public institutions of higher learning to use racial preference as a significant factor for admission when reviewing a student’s application. The court emphasized that student diversity in state schools is an undeniable state interest.
Schools can meet this state interest by narrowly tailoring their programs in a way that allows equal admission of students from different backgrounds, including race and economic status. Thus, courts are likely to find racial discrimination in school admissions constitutional as long as such a discriminatory policy is in line with the compelling interest of diversity.