United States v. Commonwealth of Virginia
United States Court of Appeals for the Fourth Circuit
976 F.2d 890 (1992)

- Written by Katrina Sumner, JD
Facts
The Virginia Military Institute (VMI) operated an educational program unlike any other program in America. Designed to produce citizen soldiers, the program featured rigorous physical training, a lack of privacy among students, living together in barracks, and an adversarial teaching style. VMI had a male-only admissions policy. Because the Commonwealth of Virginia (Virginia) (defendant) supported VMI, the United States (plaintiff) challenged the male-only admissions policy. The United States asserted that an admissions policy that excluded females regardless of their qualifications was a violation of the Equal Protection Clause of the Fourteenth Amendment. VMI countered that the all-male admissions policy supported an important state interest in educational diversity in higher education, providing an alternative to coeducation. Admitting only one gender was the only way to acquire single-gender diversity. The district court was presented with empirical studies and research showing the benefits of education in a single-gender environment for males and females alike that were not present in a coeducational context. The district court considered how admitting women would necessitate altering VMI’s unique program. For example, there was a physical test that every male student had to pass in order to graduate that would prevent a large number of women from graduating without alteration. The district court determined that Virginia had demonstrated that the men-only admissions policy served a legitimate educational objective and that the goal of achieving educational diversity was satisfied through single-gender education. The sole means of achieving this objective was to exclude women from admission at the all-male military school. The United States challenged the district court’s ruling, arguing that offering single-gender education to only males was not a legitimate government objective and that sufficient justification for the policy had not been provided.
Rule of Law
Issue
Holding and Reasoning (Niemeyer, J.)
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