Gratz v. Bollinger

539 U.S. 244 (2003)

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Nature of the Case

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Facts

Ps applied for admission to the University of Michigan's (University) College of Literature, Science, and the Arts (LSA) as residents of the State of Michigan. Both are Caucasian. D determined that, although P was “‘well qualified,’” she was “‘less competitive than the students who ha[d] been admitted on first review. P was notified in April that the LSA was unable to offer her admission. She enrolled in the University of Michigan at Dearborn, from which she graduated in the spring of 1999. Hamacher (P1) applied for admission to the LSA for the fall of 1997. P1's application was subsequently denied in April 1997, and he enrolled at Michigan State University. Ps filed a class-action suit alleging “violations and threatened violations of the rights of the plaintiffs and the class they represent to equal protection of the laws under the Fourteenth Amendment. The court granted class certification under 23(b)(2). D changed its admissions guidelines a number of times during the period relevant to this litigation. One thing was clear, D has considered African-Americans, Hispanics, and Native Americans to be “underrepresented minorities,” and it is undisputed that D admits “virtually every qualified . . . applicant” from these groups. Applicants with the same scores were subject to different admissions outcomes based upon their racial or ethnic status. In 1997, a new system was developed where, applicants could receive points for underrepresented minority status, socioeconomic disadvantage, or attendance at a high school with a predominantly underrepresented minority population, or under-representation in the unit to which the student was applying (for example, men who sought to pursue a career in nursing). An underrepresented minority applicant placed in the same cell would generally have been admitted. In 1998, a point system was adopted. This index was divided linearly into ranges generally calling for admissions dispositions as follows: 100-150 (admit); 95-99 (admit or postpone); 90-94 (postpone or admit); 75-89 (delay or postpone); 74 and below (delay or reject). An applicant was entitled to 20 points based upon his or her membership in an underrepresented racial or ethnic minority group. D also used protected seats. Specific groups - including athletes, foreign students, ROTC candidates, and underrepresented minorities - were “protected categories” eligible for these seats. The District Court determined that the admissions program the LSA began using in 1999 is a narrowly tailored means of achieving D's interest in the educational benefits that flow from a racially and ethnically diverse student body. The District Court found the admissions guidelines the LSA used from 1995 through 1998 to be more problematic. In the court's view, the University's prior practice of “protecting” or “reserving” seats for underrepresented minority applicants effectively kept nonprotected applicants from competing for those slots. The court granted P's motion for summary judgment with respect to the LSA's admissions programs in existence from 1995 through 1998, and D's motion with respect to the LSA's admissions programs for 1999 and 2000. It denied P's request for injunctive relief. Everybody appealed to the Sixth Circuit, and the Supreme Court granted certiorari to determine this case along with Grutter.