## Facts

- Jennifer Gratz and Patrick Hamacher, Michigan residents who are Caucasian, applied to the University of Michigan’s College of Literature, Science, and the Arts (LSA) and were denied admission.
- The University of Michigan’s Office of Undergraduate Admissions evaluated applicants using written guidelines that considered academic and nonacademic factors, including race.
- The University treated African-Americans, Hispanics, and Native Americans as “underrepresented minorities” and admitted virtually every qualified applicant from those groups.
- Beginning in 1998, LSA used a 150-point admissions index in which 100 points guaranteed admission.
- Under the index, applicants from underrepresented minority groups automatically received a 20-point bonus; by comparison, a perfect SAT score yielded 12 points.
- Petitioners brought a class action challenging the use of race in undergraduate admissions under the Equal Protection Clause, Title VI, and 42 U.S.C. § 1981.

## Issues

1. Whether LSA’s undergraduate admissions policy awarding automatic points based on race violates the Equal Protection Clause of the Fourteenth Amendment.
2. Whether the same policy violates Title VI of the Civil Rights Act of 1964, which bars federally funded programs from using racial classifications that would be unconstitutional under equal protection.
3. Whether the policy is narrowly tailored to any compelling interest, including the educational benefits of student body diversity.

## Decision

- The Supreme Court held, 6–3, that LSA’s admissions policy violated the Equal Protection Clause.
- Applying strict scrutiny, the Court accepted that the educational benefits of a diverse student body can be a compelling interest but held that the undergraduate points system was not narrowly tailored.
- The Court found the automatic 20-point award to all applicants in certain racial groups was mechanical and often decisive, preventing individualized evaluation of applicants’ contributions to diversity.
- The Court rejected administrative convenience (processing large numbers of applications consistently) as a justification for a racial classification.
- Because Title VI tracks equal protection standards in this setting, the policy also violated Title VI.

## Legal Principles

- Governmental racial classifications are subject to strict scrutiny and must be narrowly tailored to further a compelling governmental interest.
- Student body diversity may qualify as a compelling interest in higher education, but admissions programs must provide individualized consideration and avoid automatic racial advantages.
- Fixed, formulaic racial point allocations that make race outcome-determinative for many applicants are not narrowly tailored.
- Administrative efficiency does not justify the use of unconstitutional racial classifications.
- When a federally funded program uses race in a manner that would violate the Equal Protection Clause, it also violates Title VI.

## Conclusion

The Court invalidated the University of Michigan’s undergraduate admissions points system because its automatic, substantial racial bonus lacked individualized consideration and therefore failed narrow tailoring under strict scrutiny, rendering it unlawful under both the Equal Protection Clause and Title VI.


Gratz v. Bollinger, 539 U.S. 244 (2003)