Grutter v. Bollinger

Barbara Grutter, a white Michigan resident with a 3.8 GPA and 161 LSAT score, was denied admission to the University of Michigan Law School. The law school used a holistic admissions process that considered race as one factor among many to achieve a critical mass of underrepresented minority students. Grutter sued, alleging the school's use of race violated the Equal Protection Clause and Title VI of the Civil Rights Act.

Justice O'Connor's opinion held that strict scrutiny applies to all racial classifications but is not automatically fatal. The Court found that student body diversity is a compelling interest because it promotes cross-racial understanding, breaks down racial stereotypes, and better prepares students for an increasingly diverse workforce and society. The law school's admissions program was narrowly tailored because it used a holistic, individualized process rather than a quota; it did not insulate minority applicants from competition; it gave serious, individualized consideration to all applicants; and there were no workable race-neutral alternatives that would achieve the same diversity. O'Connor noted the Court's expectation that in 25 years, racial preferences would no longer be necessary.

Grutter provided the definitive constitutional framework for affirmative action in higher education for two decades, authorizing race-conscious admissions under strict scrutiny if narrowly tailored. The decision influenced admissions policies at universities nationwide. It was effectively overruled by Students for Fair Admissions v. Harvard in 2023, which held that race-conscious admissions programs at Harvard and UNC violated the Equal Protection Clause.