Law School Case Brief
Students for Fair Admissions, Inc. v. President & Fellows of Harvard Coll. (Harvard Corp.) - 397 F. Supp. 3d 126 (D. Mass. 2019)
Because racial characteristics so seldom provide a relevant basis for disparate treatment, race may not be considered unless the college admissions process can withstand strict scrutiny. Strict scrutiny requires the university to demonstrate with clarity that its purpose or interest is both constitutionally permissible and substantial, and that its use of the classification is necessary to the accomplishment of its purpose. The decision to pursue the educational benefits that flow from student body diversity is, in substantial measure, an academic judgment to which some, but not complete, judicial deference is proper. A university cannot impose a fixed quota or otherwise define diversity as some specified percentage of a particular group merely because of its race or ethnic origin. Once, however, a university gives a reasoned, principled explanation for its decision, deference must be given to the university's conclusion, based on its experience and expertise, that a diverse student body would serve its educational goals.
Plaintiff Students for Fair Admissions, Inc. (SFFA) initiated the present lawsuit against defendant President and Fellows of Harvard College (Harvard) for the latter’s alleged discrimination against Asian American applicants in the undergraduate admissions process to Harvard College. According to SFFA, such discrimination violated Title VI of the Civil Rights Act of 1964, 42 U.S.C.S. §§ 2000d et seq. (Title VI). Harvard moved to dismiss the lawsuit for plaintiff’s lack of standing. However, Harvard acknowledged that its undergraduate admissions process considered race as one factor among many but claimed that its use of race was consistent with applicable law.
- Did the plaintiff have standing to sue Harvard for its alleged discrimination against Asian American?
- Did the undergraduate admissions process of Harvard violate Title VI of the Civil Rights Act?
The district court held that SFFA had standing to bring a lawsuit alleging that a college discriminated against Asian American applicants in violation of Title VI of the Civil Rights Act of 1964 because its members included individuals who had standing to pursue the litigation on their own, the litigation was germane to plaintiff's purpose, and the injunctive relief sought did not require the participation of those members in the lawsuit. Anent the second issue, the court averred that Harvard’s admission process survived strict scrutiny, and therefore, it did not violate Title VI of the Civil Rights Act. According to the Court, the admission process served a compelling, permissible and substantial interest, and it was necessary and narrowly tailored to achieve diversity and the academic benefits that flowed from diversity. Applicants were afforded a holistic, individualized review, diversity was understood to embrace a broad range of qualities and experiences, and race was used as a plus factor, in a flexible, non-mechanical way.
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