Grutter v. Bollinger

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2003 United States Supreme Court case

Grutter v. Bollinger, 539 U.S. 306 (2003), was a landmark case of the Supreme Court of the United States concerning affirmative action in student admissions . The Court held that a student admissions process that favors "underrepresented minority groups " did not violate the Fourteenth Amendment 's Equal Protection Clause so long as it took into account other factors evaluated on an individual basis for every applicant. The decision largely upheld the Court's decision in _Regents of the University of California v. Bakke _ (1978), which allowed race to be a consideration in admissions policy but held racial quotas to be unconstitutional. In its companion case , _Gratz v. Bollinger _ (2003), the Court struck down a points-based admissions system that awarded an automatic bonus to the admissions scores of minority applicants.

The case arose after a prospective student to the University of Michigan Law School alleged that she had been denied admission because the school gave certain minority groups a significantly greater chance of admission. The school admitted that its admission process favored certain minority groups, but argued that there was a compelling state interest to ensure a "critical mass" of students from minority groups. In a majority opinion joined by four other justices, Justice Sandra Day O'Connor held that the Constitution "does not prohibit the law school's narrowly tailored use of race in admissions decisions to further a compelling interest in obtaining the educational benefits that flow from a diverse student body."

In her majority opinion, O'Connor wrote that "race-conscious admissions policies must be limited in time," adding that the "Court expects that 25 years from now, the use of racial preferences will no longer be necessary to further the interest approved today." Justices Ruth Bader Ginsburg and Stephen Breyer joined the Court's opinion, but did not subscribe to the belief that the affirmative measures in question would be unnecessary in 25 years. In a dissent joined by three other justices, Chief Justice William Rehnquist argued that the university's admissions system was, in fact, a thinly veiled and unconstitutional quota system.

In 2023, 20 years later, the Supreme Court effectively overruled Grutter v. Bollinger in _Students for Fair Admissions v. Harvard _. It ruled that that affirmative action in student admissions violated the Equal Protection Clause of the Fourteenth Amendment .

Dispute

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When the University of Michigan Law School denied admission to Barbara Grutter, a Michigan resident with a 3.8 GPA and 161 LSAT score , she filed this suit, alleging that respondents had discriminated against her on the basis of race in violation of the Fourteenth Amendment , Title VI of the Civil Rights Act of 1964 , as well as 42 U.S.C. § 1981; that she was rejected because the Law School uses race as a "predominant" factor, giving applicants belonging to certain minority groups a significantly greater chance of admission than students with similar credentials from disfavored racial groups; and that respondents had no compelling interest to justify that use of race. Lee Bollinger (then-President of the University of Michigan ), was the named defendant of this case.

The University argued that there was a compelling state interest to ensure a "critical mass" of students from minority groups, particularly African Americans and Hispanics, which is realized within the student body. They argued that this aims to "ensure that these minority students do not feel isolated or like spokespersons for their race; to provide adequate opportunities for the type of interaction upon which the educational benefits of diversity depend; and to challenge all students to think critically and re-examine stereotypes."

Lower courts

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In March 2001, U.S. District Court Judge Bernard A. Friedman ruled that the admissions policies were unconstitutional because they "clearly consider" race and are "practically indistinguishable from a quota system." Due to the significance of the case, the Court of Appeals agreed to hear the case _en banc _. In May 2002, in a closely divided 5–4 ruling, the Sixth Circuit Court of Appeals reversed the decision, citing the _Bakke _ decision and allowing the use of race to further the "compelling interest" of diversity. The plaintiffs subsequently requested the Supreme Court review. The Court agreed to hear the case, the first time the Court had heard a case on affirmative action in education since the landmark Bakke decision of 25 years prior.

On April 1, 2003 the US Supreme Court heard oral arguments for Grutter. The Court allowed the recordings of the arguments to be released to the public the same day, only the second time the Court had allowed same-day release of oral arguments. The first time was _Bush v. Gore _, 531 U.S. 98 (2000), the case that ultimately ended the 2000 presidential election .

Supreme Court's decision

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The Court's majority ruling, authored by Justice Sandra Day O'Connor , held that the United States Constitution "does not prohibit the law school's narrowly tailored use of race in admissions decisions to further a compelling interest in obtaining the educational benefits that flow from a diverse student body." The Court held that the law school's interest in obtaining a "critical mass" of minority students was indeed a "tailored use". O'Connor noted that sometime in the future, perhaps twenty-five years hence, racial affirmative action would no longer be necessary in order to promote diversity. It implied that affirmative action should not be allowed permanent status and that eventually a "colorblind" policy should be implemented. The opinion read, "race-conscious admissions policies must be limited in time." "The Court takes the Law School at its word that it would like nothing better than to find a race-neutral admissions formula and will terminate its use of racial preferences as soon as practicable. The Court expects that 25 years from now, the use of racial preferences will no longer be necessary to further the interest approved today." The phrase "25 years from now" was echoed by Justice Thomas in his dissent. Justice Thomas, writing that the system was "illegal now", concurred with the majority only on the point that he agreed the system would still be illegal 25 years hence.

The decision largely upheld the position asserted in Justice Powell's concurrence in _Regents of the University of California v. Bakke , which allowed race to be a consideration in admissions policy, but held that quotas were illegal.[citation needed
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Public universities and other public institutions of higher education across the nation are now allowed to use race as a plus factor in determining whether a student should be admitted. While race may not be the only factor, the decision allows admissions bodies to take race into consideration along with other individualized factors in reviewing a student's application. O'Connor's opinion answers the question for the time being as to whether "diversity" in higher education is a compelling governmental interest. As long as the program is "narrowly tailored" to achieve that end, it seems likely that the Court will find it constitutional.[_citation needed
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In the majority were Justices O'Connor, Stevens, Souter, Ginsburg, and Breyer. Chief Justice Rehnquist and Justices Scalia, Kennedy, and Thomas dissented. Much of the dissent concerned a disbelief in the validity of the law school's claim that the system was necessary to create a "critical mass" of minority students and provide a

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