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DeFunis v. Odegaard

Citations: 529 P.2d 438; 84 Wash. 2d 617; 1974 Wash. LEXIS 768Docket: 42198

Court: Washington Supreme Court; December 12, 1974; Washington; State Supreme Court

Narrative Opinion Summary

The case of DeFunis v. Odegaard involves a challenge to the University of Washington School of Law's admissions policy, which was alleged to violate the Equal Protection Clause by favoring minority candidates over more qualified non-minority applicants. Initially, a Superior Court ruled in favor of DeFunis, mandating his admission. However, this decision was reversed by the Washington Supreme Court, which upheld the admissions policy. DeFunis sought relief from the U.S. Supreme Court, which granted certiorari but ultimately deemed the case moot, as DeFunis was nearing graduation. The Supreme Court vacated the prior judgment and remanded the case. Subsequently, DeFunis attempted to convert the case into a class action to address similar grievances for other applicants, but this was denied due to inadequate representation and competing interests, as outlined in CR 23(a). The Washington Supreme Court reaffirmed its initial judgment, emphasizing the public interest in addressing the legality of considering racial or ethnic backgrounds in admissions. Despite dissenting opinions on the mootness and class action status, the case highlights the judicial navigation of equal protection principles, mootness doctrine, and class action requirements, culminating in a decision that upheld the law school's policy and denied further class action proceedings.

Legal Issues Addressed

Class Action Suit Requirements under CR 23(a)

Application: The court denied the motion to designate the case as a class action, ruling that it did not meet the criteria under CR 23(a), particularly due to a lack of adequate representation and competing interests.

Reasoning: The court denied this motion, affirming that it did not meet the criteria for a class action as outlined in Washington's CR 23(a).

Equal Protection Clause and Minority Admissions Policies

Application: The case challenged the University of Washington School of Law's minority admissions policy, alleging it violated the Equal Protection Clause by favoring less qualified minority applicants over more qualified non-minority applicants.

Reasoning: DeFunis was among the 1,271 denied admission and challenged the minority admissions policy, claiming it violated equal protection by granting preference to less qualified minority applicants.

Judicial Discretion on Moot Cases

Application: The Supreme Court exercises discretion in vacating and remanding moot cases to prevent lower appellate rulings from being enforceable when the underlying basis has vanished.

Reasoning: The Supreme Court exercises its discretionary appellate supervisory power to reverse and remand moot cases from lower federal courts based on two main theories...

Mootness Doctrine in Judicial Proceedings

Application: The U.S. Supreme Court found the case moot because DeFunis was set to graduate regardless of the outcome, rendering the dispute non-justiciable.

Reasoning: The Supreme Court ultimately deemed the case moot, stating that the dispute was no longer 'definite and concrete.'