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| Students for Fair Admissions v. University of North Carolina | |
|---|---|
| Case name | Students for Fair Admissions v. University of North Carolina |
| Full name | Students for Fair Admissions, Inc. v. University of North Carolina and Thomas W. Ross, in his official capacity as President of the University of North Carolina |
| Citation | 597 U.S. ___ (2023) |
| Decided | June 29, 2023 |
| Docket | 20-1199 |
| Prior | Students for Fair Admissions, Inc. v. President and Fellows of Harvard College (D. Mass.); Students for Fair Admissions, Inc. v. President and Fellows of Harvard College, cert. granted |
| Holding | Race-conscious admissions programs at public universities are unconstitutional under the Equal Protection Clause as applied in this case |
| Majority | Roberts |
| Joinmajority | Thomas, Alito, Gorsuch, Kavanaugh |
| Concurrence | Thomas (concurring) |
| Dissent | Kagan |
| Joindissent | Sotomayor, Jackson |
| Laws applied | U.S. Const. amend. XIV |
Students for Fair Admissions v. University of North Carolina is a 2023 United States Supreme Court decision addressing race-conscious admissions at public universities under the Equal Protection Clause of the Fourteenth Amendment. The case originated from litigation challenging the University of North Carolina at Chapel Hill's undergraduate admissions practices and was consolidated with related challenges to Harvard College in a separate but companion matter. The Court's ruling curtailed use of race as a factor in selective admissions and reshaped jurisprudence involving affirmative action, higher education policy, civil rights litigation, and administrative law.
The dispute arose amid decades of litigation over affirmative action at selective institutions, following precedents set by Regents of the University of California v. Bakke, Grutter v. Bollinger, and Gratz v. Bollinger. Plaintiffs challenged policies at University of North Carolina at Chapel Hill, citing admissions practices similar to those at Harvard College, Yale University, Princeton University, Columbia University, and University of Pennsylvania. The case involved factual inquiries into admissions modeling, demographic trends, and legacy and donor preferences at institutions like Duke University, Northwestern University, Stanford University, Massachusetts Institute of Technology, California Institute of Technology, and University of Michigan. Background reporting and filings referenced actors including former presidents such as Nathan Hatch, administrators like Thomas W. Ross, and advocacy groups such as Students for Fair Admissions, Alliance Defending Freedom, and civil rights organizations including NAACP Legal Defense and Educational Fund.
The principal plaintiff, Students for Fair Admissions, led by founder Edward Blum, brought suit against defendants including University of North Carolina at Chapel Hill and its president Thomas W. Ross. The complaint alleged violations of the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution, invoking standards articulated in cases like Brown v. Board of Education and subsequent affirmative action jurisprudence. Defendants included university administrators, faculty governance bodies, and policy officers, with amici briefs from entities such as American Association of University Professors, United Negro College Fund, American Council on Education, Association of American Medical Colleges, Brennan Center for Justice, Liberty Counsel, and state officials from North Carolina. Intervenors and amici also included private foundations like the Carnegie Corporation, corporations such as Microsoft Corporation and Google LLC, and international institutions referencing practices in United Kingdom and Canada contexts.
Initial proceedings occurred in the United States District Court for the Middle District of North Carolina before Judge Maxwell (presiding), with extensive discovery, depositions, and statistical analyses led by experts from institutions including Harvard College, Duke University, Rice University, University of California, Berkeley, and University of Chicago. The district court applied precedents like Grutter v. Bollinger and evaluated race-conscious policies against strict scrutiny, considering testimony from administrators, admissions officers, and statisticians. The judgment was appealed to the United States Court of Appeals for the Fourth Circuit, where panels considered equal protection doctrine, remedial relief, and standards from the Fourteenth Amendment to the United States Constitution and statutory contexts such as Title IX disputes addressed in Grove City College v. Bell and administrative deference issues traced to Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc..
The Supreme Court granted certiorari, consolidating review with a companion case concerning Harvard College. Oral arguments featured advocates including counsel associated with Harvard and with plaintiff groups, with questions referencing precedents like Grutter v. Bollinger, Regents of the University of California v. Bakke, and decisions by justices including Sandra Day O'Connor, Anthony Kennedy, and former clerks from chambers such as John G. Roberts Jr. and Elena Kagan. Amicus briefs were filed by an array of institutions: universities including Princeton University and Yale University; civil rights groups including NAACP and LULAC; corporations including Amazon.com, Inc. and Apple Inc.; and states represented by attorneys general from jurisdictions such as California and Texas.
Central legal issues included whether race-conscious admissions programs could satisfy strict scrutiny and whether the university had articulated a compelling interest and narrowly tailored means consistent with Grutter v. Bollinger. Plaintiffs argued that race-based preferences violated the Equal Protection Clause and produced racial balancing proscribed in Bakke. Defendants argued that diversity constitutes a compelling interest supported by educational benefits recognized in rulings involving institutions like University of Michigan and by social science research from scholars at Columbia University, Stanford University, and Harvard University. Amici presented empirical analyses from scholars at Princeton University, Yale University, University of Texas at Austin, and policy organizations including the Brookings Institution and American Enterprise Institute.
In a majority opinion authored by Chief Justice John Roberts, the Court held that the University of North Carolina's race-conscious admissions practices violated the Equal Protection Clause. The opinion overruled or limited aspects of prior precedent such as Grutter v. Bollinger, emphasizing textualist and originalist readings associated with scholars and jurists like Antonin Scalia and Robert Bork. The majority applied strict scrutiny and found that the university's use of race was not narrowly tailored, referencing administrative records and statistical evidence from the district court. Justice Clarence Thomas wrote a concurring opinion arguing for broader doctrinal changes. Justice Elena Kagan filed a dissent, joined by Justices Sonia Sotomayor and Ketanji Brown Jackson, defending precedents that endorsed narrowly tailored consideration of race to achieve educational diversity.
The decision prompted immediate responses from higher education leaders at institutions including University of North Carolina at Chapel Hill, Harvard University, Yale University, Princeton University, and Stanford University, and statements from civil rights organizations such as NAACP Legal Defense and Educational Fund and American Civil Liberties Union. Legislative and executive actors from state governments including North Carolina, California, Texas, and New York signaled policy reviews. Scholars at universities like Columbia University, University of Chicago, Duke University, and think tanks including the Brookings Institution and Heritage Foundation debated implications for diversity initiatives, admissions models, and pipeline programs such as those run by UNCF and Teach For America. The ruling affected related litigation involving public and private institutions, prompted revisions to admissions policies at law schools like University of Michigan Law School and medical schools such as Johns Hopkins University School of Medicine, and influenced ongoing debates in contexts including employment law disputes before the Equal Employment Opportunity Commission and education policy deliberations in state legislatures and at intergovernmental bodies like the United Nations Human Rights mechanisms.