Gratz v. Bollinger, 539 U.S. 244 (2003)
Gratz v. Bollinger is one of the Supreme Court's landmark affirmative action decisions, issued the same day as Grutter v.
Does the University of Michigan's undergraduate admissions policy, which automatically awards a fixed number of points to every underrepresented minority applicant in pursuit of diversity, violate the Equal Protection Clause of the Fourteenth Amendment and, by extension, Title VI?
Racial classifications by a state actor are subject to strict scrutiny and must be justified by a compelling governmental interest and be narrowly tailored to achieve that interest. Student body diversity in higher education can be a compelling interest (consistent with Bakke and affirmed in Grutter), but the means employed must provide individualized consideration and cannot function as a quota or mechanical award that makes race decisive for many applicants. Title VI of the Civil Rights Act prohibits race discrimination by federally funded programs and is coextensive with the Equal Protection standards for intentional discrimination.
Yes. The LSA's automatic award of 20 points to every underrepresented minority applicant, without individualized consideration, is not narrowly tailored to the asserted compelling interest in diversity and violates the Equal Protection Clause and Title VI. The judgment was affirmed in part, reversed in part, and remanded for appropriate relief.
Gratz draws a bright doctrinal line: while diversity can be a compelling interest, admissions systems cannot use rigid, mechanical racial preferences. The case, paired with Grutter, teaches that narrow tailoring demands individualized, holistic review and disallows automatic point bonuses tied to race. It has guided universities in designing admissions policies and influenced later cases like Fisher I and II, which reiterated that courts must meaningfully enforce strict scrutiny and reject policies that treat race as decisive without individualized assessment.