Gratz v. Bollinger
Headline: University of Michigan’s undergraduate race-based point system struck down, blocking automatic 20-point minority bonus and making it harder for the school to use race as a decisive admissions shortcut for many applicants.
Holding: The Court held that the University of Michigan's undergraduate admissions policy that automatically gives 20 points to underrepresented minority applicants is not narrowly tailored and therefore violates the Fourteenth Amendment, Title VI, and §1981.
- Strikes down automatic 20-point race bonus in Michigan undergraduate admissions.
- Requires meaningful, individualized review when race is considered in admissions.
- Remands for further proceedings consistent with the Court’s ruling.
Summary
Background
Two white applicants, Jennifer Gratz and Patrick Hamacher, applied to the University of Michigan’s College of Literature, Science, and the Arts and were denied admission. They filed a class-action lawsuit arguing the school’s admissions rules used race in ways that violated the Equal Protection Clause (which bars unequal state treatment), Title VI, and §1981. The District Court struck down older rules from 1995–1998 but upheld the 1999–2000 selection index that awarded automatic race points; this case reached the Supreme Court to review that ruling.
Reasoning
The Court asked whether the University’s method of considering race in undergraduate admissions met strict scrutiny—meaning the policy had to serve a truly important government interest and be narrowly tailored. The University said it sought educational benefits from diversity. The Court found the 1999 selection index problematic because it automatically awarded 20 points to every underrepresented minority applicant, making race decisive for many minimally qualified applicants and preventing meaningful, individual consideration. The Admissions Review Committee review was limited and came after the automatic bonus. Because the automatic bonus was not narrowly tailored, the Court held it unlawful and reversed the portion of the District Court decision that had upheld the policy.
Real world impact
The ruling invalidates the LSA’s mechanical 20-point bonus and sends the case back for further proceedings consistent with the opinion. It requires the University (and similarly structured programs) to reconsider admissions methods so that race, if considered, is applied through meaningful individualized review rather than an automatic points shortcut.
Dissents or concurrances
Several Justices wrote separate opinions: Justice O’Connor (joined in part by Breyer) stressed lack of individualized review; Justice Thomas would broadly prohibit race-based admissions; Justices Stevens, Souter, and Ginsburg dissented or would have reached different conclusions on standing or tailoring.
Opinions in this case:
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