Facts
- The University of California, Davis School of Medicine used two admissions tracks: a regular program and a special program for “economically and/or educationally disadvantaged” applicants from specified minority groups.
- The special program effectively reserved 16 of 100 seats in each entering class for those minority applicants and filled those seats separately from the general applicant pool.
- The special admissions committee did not apply the regular program’s 2.5 GPA cutoff and did not rank special-program candidates against the general pool.
- Allan Bakke, a white applicant, was denied admission in 1973 and 1974 despite academic metrics higher than those of some minority applicants admitted through the special program.
- Bakke alleged he was excluded from consideration for all 100 seats because of race.
Issues
- Whether the medical school’s 16-seat set-aside for specified minority applicants violated the Equal Protection Clause of the Fourteenth Amendment.
- Whether the set-aside violated Title VI of the Civil Rights Act of 1964 as applied to a federally funded university program.
- Whether a university may consider race in admissions as part of an individualized selection process to further educational diversity.
Decision
- The Court affirmed in part and reversed in part the state court judgment in a fragmented decision; Justice Powell’s opinion supplied the controlling rationale.
- A majority invalidated the 16-seat set-aside and ordered that Bakke be admitted.
- A different majority concluded that race-conscious admissions are not categorically unlawful and that race may be considered as one factor among many in individualized review.
- The Court rejected fixed, race-based reservations of seats that operate as an exclusionary quota for nonminority applicants.
Legal Principles
- Racial classifications by a state actor are subject to strict scrutiny, including classifications described as remedial or benign.
- A rigid set-aside that reserves a fixed number of seats for specified racial groups is not narrowly tailored and violates equal protection.
- Title VI, in this context, was treated as barring the same race discrimination prohibited by the Equal Protection Clause for federally funded programs.
- A university may pursue the educational benefits of a diverse student body as a compelling interest and may consider race as a “plus” factor within an individualized, competitive process for all seats.
- An admissions system is more likely to satisfy constitutional limits when it avoids automatic racial barriers or guarantees and evaluates each applicant as an individual across multiple attributes.
Conclusion
The Court required Bakke’s admission and struck down UC Davis’s fixed minority seat reservation as unlawful racial discrimination, while allowing universities to consider race in admissions only as part of individualized review aimed at achieving the educational benefits of student-body diversity without employing quotas.