United States v. Virginia

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Citation. 518 U.S. 515, 116 S. Ct. 2264, 135 L. Ed. 2d 735, 1996 U.S. 4259.

Brief Fact Summary. Virginia Military Institute (VMI) was the only single-sexed school in Virginia. VMI used a highly adversarial method to train (male) leaders of the future. There was no equal educational opportunity to that of VMI in the State for women.

Synopsis of Rule of Law. Gender-based classifications of the government can be defended only by exceedingly persuasive justifications. The State must show that its classification serves important governmental objectives and that the means employed are substantially related to those objectives. The justification must be genuine, not hypothesized. And it must not rely on overbroad generalizations about the differences between males and females.

Facts. VMI was the sole single-sexed school among Virginia’s 15 public institutions. VMI’s mission is to produce “citizen soldiers”�, (male) leaders of the future. VMI achieves its mission through its “adversative method”�, which is characterized by physical rigor, mental stress, absolute equality of treatment, absence of privacy, etc. At trial, the District Court acknowledged that women were missing out on a unique educational opportunity, but upheld the school’s policy on the rationale that admitting women could not be done without compromising the school’s adversative method. Pursuant to a decision by the Court of Appeals, the State established the Virginia Women’s Institute for Leadership (VWIL) for women. VWIL offered fewer courses than VMI and was run without the adversative method.

Issue. Did VMI represent a violation of the Fourteenth Amendment’s Equal Protection Clause?