Grutter v. Bollinger involved a challenge to affirmative action at the University of Michigan. Grutter and its companion case, Gratz v. Bollinger, evaluated the constitutionality of the use of race in admissions by the law school and the undergraduate program at Michigan, respectively. In a 5–4 decision in Grutter, the U.S. Supreme Court upheld the law school's practice of using race as part of a holistic review of applicants. At the same time, in Gratz, the justices rejected the college's use of a point system that attached fixed numerical weights to race as unduly rigid.

In Grutter, the Court made clear that affirmative action on the basis of race triggers strict judicial scrutiny, which requires narrowly tailored means to achieve a compelling government interest. In an ...

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