Texas v. Lesage
Headline: University’s use of race in Ph.D. admissions overturned in part; Court ruled schools can avoid damages claims by proving they would have rejected the applicant even without considering race, easing liability for universities.
Holding: The Court held that if a university proves it would have rejected an applicant even without considering race, that showing defeats a damages claim because no cognizable injury occurred.
- Blocks damages claims when a school proves the same decision would have occurred without race.
- Makes it harder for rejected applicants to recover money if denial would be the same.
- Leaves injunctive and other statutory claims to be decided on remand.
Summary
Background
An African immigrant of Caucasian descent applied to a University of Texas Ph.D. program in counseling psychology for 1996–1997. The program received 223 applications and admitted about 20 people. The school acknowledged that race was considered at some stage, and it admitted at least one minority applicant. The applicant was rejected and sued for money and an order to stop race-based admissions, claiming the school’s race-conscious process violated federal civil-rights laws. The school moved for summary judgment, offering evidence that many applicants had higher GPAs and GRE scores and that a committee member described the applicant’s statement and recommendations as weak.
Reasoning
The central question was whether the applicant could recover money damages even if the school showed it would have denied him under a race-neutral review. The Supreme Court explained that longstanding law allows a government defendant to avoid liability by proving it would have made the same decision without the improper consideration. The Court concluded that if it is undisputed the school would have rejected the applicant regardless of race, then the applicant suffered no legally cognizable injury for a damages claim. The Court reversed the appeals court’s decision that had sent the case to trial on that damages issue and sent the case back for proceedings consistent with this ruling.
Real world impact
This ruling means rejected applicants will have a harder time winning money damages when a school proves the same outcome would have happened without considering race. The Court left open whether the applicant’s other statutory claims or any request for an injunction against a continuing race-conscious program remain, and those issues go back to the lower court.
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