DeFunis v. Odegaard
Headline: Law school race-based admissions fight is dismissed as moot; Court vacates state ruling, letting the student finish law school while declining to decide the admissions constitutional claim.
Holding: The Court held the dispute was moot because the student could complete his final term and diploma regardless of the decision, vacated the state-court judgment, and declined to decide the admissions constitutional claim.
- Leaves law school race-based admissions unresolved and open to future lawsuits.
- Allows DeFunis to complete law school without a substantive ruling.
- Signals broad public interest with many amici participating.
Summary
Background
In 1971 Marco DeFunis applied to the University of Washington Law School. The school received about 1,601 applications for roughly 150 first-year places. The admissions committee calculated a numeric Predicted First Year Average from LSAT scores and college grades. The school ran a minority admissions program that separately reviewed applicants who identified as black, Chicano, American Indian, or Filipino and compared them only with one another. DeFunis’s Average was 76.23; he was placed on the waiting list, ranked low, and denied a spot. Thirty-seven minority applicants were admitted, most with Averages below DeFunis’s score.
Reasoning
The Court’s central question was whether the case remained a live dispute that it could decide. Because DeFunis had been admitted, remained enrolled, and had registered for his final term, the majority concluded that any ruling could not change his right to finish law school. The Per Curiam opinion therefore held the case moot under Article III, vacated the Washington Supreme Court’s decision, and remanded for further state-court proceedings. The Court expressly declined to resolve the constitutional challenge to the law school’s race-based admissions procedure.
Real world impact
Because the Supreme Court did not reach the merits, the law school’s admissions policy was left unresolved by this decision. The outcome means the specific constitutional question about treating minority applicants separately was not settled here and could be litigated again. The record and briefs show wide public interest, and many groups filed amicus briefs urging review.
Dissents or concurrances
Justices Brennan and Douglas dissented, arguing the controversy was not moot and the Court should decide the constitutional issues. Justice Douglas urged a new trial to examine admissions practices and whether minority treatment was lawful.
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