Regents of Univ. of California v. Bakke

Brief Fact Summary.

A white medical student was denied admission to the Medical School of the University of California at Davis due to the implementation of a special admissions program designed to assure the admission of a specified number of minority students, thereby limiting the number of white students. Strict scrutiny was used to invalidate the medical school’s admission policy.

Synopsis of Rule of Law.

When a classification denies an individual opportunities or benefits enjoyed by others solely because of his race or ethnic background, as here, it must be regarded as suspect. When a state’s distribution of benefits or imposition of burdens hinges on the person’s color of skin or ancestry, that individual is entitled to a demonstration that the challenged classification is necessary to promote a substantial state interest. Merely filling a racial quota is not a substantial state interest and thus, is per se unconstitutional.

Facts.

Respondent, Mr. Bakke, challenged a special admissions policy implemented by the Petitioner, Medical School of the University of California at Davis, claiming that he was unconstitutionally denied admission based on this policy. The policy was designed to assure the admission of a specified number of minority groups. The State Supreme Court of California held the special admissions program unlawful, enjoined Petitioner from considering the race of any applicant and ordered Respondent’s admission.

Issue.

Whether strict scrutiny should be the level of judicial scrutiny applied to the special admissions program.
Whether the purpose of “reducing the historic deficit of traditionally disfavored minorities in medical schools and the medical profession is constitutionally permissible as to satisfy strict scrutiny.
Whether the purpose of countering the effects of societal discrimination is constitutionally permissible to satisfy strict scrutiny.
Whether the purpose of increasing the number of doctors in underserved communities is constitutionally permissible to satisfy strict scrutiny.
Whether the purpose of creating a diverse student population is constitutionally permissible to satisfy strict scrutiny.

Held.

Yes. Judgment of the State of California Supreme Court affirmed. When a classification denies an individual opportunities or benefits enjoyed by others solely because of his race or ethnic background (as here), it must be regarded as suspect. Since a suspect class is being discriminated against, strict scrutiny must be applied to the special admissions program.
No. Preferring members of any one group for no reason other than race or ethnic origin is discrimination for its own sake and is forbidden by the United States Constitution. If Petitioner’s purpose is to ensure a certain percentage of a particular group based on its race or ethnic origin, such a preferential purpose is invalid.
No. The state has a legitimate and substantial interest in ameliorating or eliminating the disabling effects of social discrimination. The government has no greater interest in helping one individual than in refraining from another. Therefore, the purpose in helping certain groups whom the faculty of the Petitioner perceived as victims of “societal discrimination” does not justify a classification that imposes disadvantages upon persons such as Respondent.
No. There is virtually no evidence indicating that Petitioner’s special admissions policy is either needed or geared to promote that goal.
Yes. Diversity is clearly a constitutionally permissible interest for an institution of higher education, as the interest of diversity is compelling in the context of a university’s admission program. The question remains, however, whether the program’s racial classification is necessary to promote this interest. Here, Petitioner’s special admissions program focused solely on ethnic diversity, would hinder rather than further attainment of overall diversity. Therefore, the special admissions program is unconstitutional.

Dissent.

Since whites are not a minority, only intermediate review should be used. Therefore, the affirmative admissions program is entirely constitutional.
Concurrence. The question whether race can ever be used as a factor in an admissions decision is not an issue in this case and discussion of that issue is inappropriate.

Discussion.

This highly divided case applies strict scrutiny to a higher education admissions policy rendering the policy invalid because the policy was based, in part, on a quota system.