Grutter v. Bollinger
Citation
539 U.S. 306 (2003)
Facts
The University of Michigan Law School used a highly individualized, holistic admissions system that considered race as one of many “plus factors” in assembling a diverse student body. Applicants were not given points for race (unlike the undergraduate system struck down in Gratz v. Bollinger); instead, admissions officers engaged in individualized review giving serious consideration to each applicant’s contributions to diversity, including racial and ethnic background.
Issue
Is the University of Michigan Law School’s race-conscious admissions program — using race as one factor in an individualized holistic review — consistent with the Equal Protection Clause?
Holding
Yes. Justice O’Connor, writing for a 5–4 majority, held that student body diversity is a compelling governmental interest and that the law school’s admissions program was narrowly tailored to achieve that interest.
Rule / Doctrine
Affirmative action in higher education: racial classifications trigger strict scrutiny. Student body diversity constitutes a compelling interest. A holistic, individualized program that treats race as one factor among many — with no quotas and no mechanical point system — can be narrowly tailored. O’Connor predicted that race-conscious programs should not be necessary in 25 years.
Significance
Grutter (together with Gratz) defined the constitutional limits of race-conscious admissions for nearly two decades. It was effectively overruled by Students for Fair Admissions v. Harvard (2023), which held race-conscious admissions programs at Harvard and UNC unconstitutional. Grutter remains important for understanding the doctrinal evolution of affirmative action under the Equal Protection Clause.