Smith v. University of Washington
United States Court of Appeals for the Ninth Circuit
392 F.3d 367 (2004)
- Written by Jennifer Flinn, JD
Facts
Katuria Smith, Angela Rock, and Michael Pyle (Smith) (plaintiffs) were White applicants who were denied admission to the University of Washington Law School (defendant). The law school’s admissions program sought to ensure a diverse student body and, in doing so, considered an applicant’s race as one factor in the admissions process. The law school did not establish racial quotas or goals, but the school did give applicants of certain races and ethnicities a “plus” when making an admission decision. The law school used an index score consisting of the applicant’s undergraduate grade point average and Law School Admission Test score to rank applicants. In addition to this index score, the law school considered race and ethnicity and other diversity factors not involving race to make admissions decisions. These factors included life experiences and accomplishments, extracurricular activities, coming from a disadvantaged environment, and career goals. Based on these factors, more White applicants were admitted with lower index scores than other races. If an application indicated that the applicant was a racial minority, the law school sent an ethnicity substantiation letter requesting more information on how race or ethnicity had affected the applicant’s life. White students were allowed to supplement their applications on the students’ initiative. Asian American applicants came from various countries and cultural backgrounds and were given a “plus” during the admissions process to admit a diverse population of Asian Americans. Applications could be admitted by a single admissions administrator or referred to an admissions committee based on race and index score. Smith filed a lawsuit pursuant to 42 U.S.C. § 1981, § 1983, and Title VI of the Civil Rights Act of 1964, alleging that the law school had discriminated against the applicants based on race. The trial court ruled in favor of the law school, and Smith appealed.
Rule of Law
Issue
Holding and Reasoning (Fisher, J.)
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