Regents of the University of California v. Bakke

1978-06-28

Headline: Medical-school racial‑slot plan struck down, ordering a rejected white applicant admitted, while the Court allows race as one factor but limits fixed quotas in university admissions (affects applicants and schools nationwide).

Holding: The Court held that the Davis Medical School's fixed racial‑slot special admissions program was unlawful, ordered a white applicant admitted, but said race may be considered as one factor in properly tailored university admissions.

Real World Impact:

Strikes down fixed racial‑slot quotas in college admissions.
Allows race to be considered as one factor in admissions.
Applicants denied solely by quota may obtain court relief.

Topics: college admissions, affirmative action, race and admissions, civil rights law, medical school admissions

Summary

Background

A white applicant applied to the University of California, Davis, Medical School in 1973 and 1974 and was denied both times. The school ran a separate special admissions track that reserved 16 of 100 places for certain minority groups and evaluated those applicants separately. The trial court found that the program acted as a racial quota, enjoined the school from considering race, and refused to order the applicant admitted. The California Supreme Court affirmed that the special program was unlawful and then directed the trial court to admit the applicant when the university conceded it could not show he would not have been admitted absent the program.

Reasoning

The central question was whether the Davis special admissions program unlawfully excluded individuals from a federally supported program on the ground of race. The Supreme Court concluded that the particular fixed‑slot special admissions plan was unconstitutional as applied and that the rejected applicant was entitled to admission. At the same time, the Court held that the courts below erred in imposing a total ban on any consideration of race in admissions. In short, the Davis program’s explicit racial slots were invalid, but the Court left room for properly designed, limited race‑conscious admissions measures.

Real world impact

The decision removes employer or school use of explicit fixed racial slots like Davis used, and it gives courts and universities a framework: blatant quota systems are unlawful, but race may be a limited consideration to achieve legitimate educational goals. The opinion split the Justices, producing guidance but not a single detailed formula for every admissions policy, so many schools will need to revise programs and may face more litigation.

Dissents or concurrances

The Justices were divided. Some joined the judgment that Bakke must be admitted but would allow broader race‑conscious remedies to address past discrimination; others rejected the specific quota at Davis while permitting narrowly tailored consideration of race.