Summary
The Supreme Court held that the Equal Protection Clause of the Fourteenth Amendment does not prohibit Michigan's constitutional amendment banning affirmative action in public university admissions.
Topics
Practice areas
Questions Presented
- Whether Michigan's constitutional amendment prohibiting race‑based preferences in public university admissions violates the Equal Protection Clause of the Fourteenth Amendment.
- Whether the political‑process doctrine articulated in Washington v. Seattle and Hunter v. Erickson applies to the amendment.
Holdings
- The amendment is constitutional; the judgment of the Sixth Circuit is reversed.
Key quotations
“There is no authority in the Federal Constitution or in this Court’s precedents for the Judiciary to set aside Michigan laws that commit to the voters the determination whether racial preferences may be considered in governmental decisions, in particular with respect to school admissions.” (at 4–5)
“The Constitution creates a democratic political system through which the people themselves must together find answers to disagreements of this kind.” (at 15–16)
Factual background
Michigan voters adopted Proposal 2, amending the state constitution to prohibit any race‑based preferences in public university admissions. The amendment was challenged by the Coalition to Defend Affirmative Action (BAMN) and others as a violation of the Equal Protection Clause.
Procedural history
The Eastern District of Michigan granted summary judgment to Michigan, upholding the constitutional amendment prohibiting race‑based preferences. The Sixth Circuit reversed, holding the amendment violated the political‑process doctrine. The Supreme Court granted certiorari and reversed the Sixth Circuit.
Remand instructions
The judgment of the Court of Appeals is reversed and the case is so ordered.