Grutter v. Bollinger

Background & Context

Barbara Grutter was a white Michigan resident who applied to the University of Michigan Law School in 1996. She had a 3.8 undergraduate GPA and an LSAT score of 161 — above average. She was rejected twice. She sued, arguing that the law school's admissions process discriminated against her because of her race in violation of the Equal Protection Clause of the Fourteenth Amendment and Title VI of the Civil Rights Act. The University of Michigan Law School used a "holistic" admissions process designed to produce a "critical mass" of underrepresented minority students — primarily Black, Hispanic, and Native American applicants. Admissions officers were instructed to consider race as one factor among many, including undergraduate GPA, LSAT scores, work experience, personal statements, letters of recommendation, and geographic background. The school did not use a point system or set quotas. Dean Jeffrey Lehman acknowledged that race was a "plus factor" for minority applicants and that the school sought to ensure meaningful representation. The case was decided alongside Gratz v. Bollinger, which challenged the University of Michigan's undergraduate admissions process. The undergraduate process used a point system that awarded 20 points automatically to members of underrepresented minority groups — and that system was struck down 6-3 as mechanically applying race in a way that was not sufficiently individualized. Grutter, by contrast, focused on the law school's more flexible, individualized approach.