Students for Fair Admissions, Inc. v. President & Fellows of Harvard Coll. - 980 F.3d 157 (1st Cir. 2020)

Rule:

There is no requirement that universities use entirely objective criteria when considering race to admit applicants.

Facts:

Students for Fair Admissions, Inc. (“SFFA”) brought suit against the President and Fellows of Harvard College and the Board of Overseers (collectively, "Harvard"), alleging that Harvard College’s admittedly race-conscious undergraduate admissions process violated Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq. ("Title VI") by discriminating against Asian American applicants in favor of white applicants. SFFA asserted that Harvard failed to meet the Supreme Court’s standards for the use of race in admissions. The district court denied Harvard's motion to dismiss SFFA's suit for lack of Article III standing. After trial, the district court, Harvard had a compelling interest in student body diversity that was sufficiently precise to permit judicial scrutiny. It concluded that Harvard had met its burden of showing its admissions process did not violate Title VI. SFFA challenged the decision.

Issue:

Did Harvard College’s race-conscious undergraduate admissions process violate Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq?

Answer:

No.

Conclusion:

The Court held that the student group had associational standing to bring its claims and the indicia of membership test did not apply since the group was, on its face, a voluntary membership organization. Under governing Supreme Court law, university's race-conscious admissions program did not violate Title VI of the Civil Rights Act of 1964 as the fact that the university's application process was subjective was insufficient to overcome other evidence in the record that the university was not biased against Asian Americans and did not stereotype them. According to the Court, there was no requirement that the university use entirely objective criteria when considering race to admit applicants. As such, the district court did not clearly err in finding that the university did not intentionally discriminate against Asian Americans.