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Students for Fair Admissions, Inc. v. President & Fellows of Harvard Coll.

Citation: 346 F. Supp. 3d 174Docket: Civil Action No. 14-cv-14176-ADB

Court: District Court, District of Columbia; September 28, 2018; Federal District Court

Narrative Opinion Summary

The case involves allegations by Students for Fair Admissions (SFFA) against Harvard University, claiming that its undergraduate admissions process discriminates against Asian Americans, violating Title VI of the Civil Rights Act of 1964. SFFA asserts that Harvard engages in intentional discrimination, racial balancing, and fails to consider race-neutral alternatives adequately. The court denied cross-motions for summary judgment, citing substantial factual disputes that necessitate a trial. The court emphasized the need for a fact-intensive inquiry, influenced by conflicting expert testimony regarding the impact of race on admissions outcomes. Harvard's defense relies on the argument that its admissions policies are aligned with legal precedents on diversity and educational benefits. SFFA maintains that Harvard's practices result in lower personal ratings for Asian American applicants, effectively reducing their admissions chances. The court affirmed SFFA's associational standing to sue on behalf of its members, including rejected Asian American applicants, and rejected Harvard's mootness claims, as standing members expressed readiness to transfer if race-based admissions were eliminated. The trial will address the credibility of expert testimonies, the validity of statistical analyses, and the adequacy of race-neutral alternatives in achieving diversity.

Legal Issues Addressed

Evaluation of Race-Neutral Alternatives

Application: The Court requires Harvard to demonstrate that race-neutral alternatives cannot achieve the same diversity benefits as its current race-conscious admissions policy.

Reasoning: Under strict scrutiny, Harvard bears the burden of proving that no effective race-neutral alternatives are available before resorting to race in admissions.

Intentional Discrimination and Statistical Evidence

Application: Conflicting expert testimony and statistical analyses regarding the impact of race on admissions decisions necessitate a trial to resolve disputes.

Reasoning: The court notes that the heavy reliance on statistical evidence and expert testimony prevents the granting of summary judgment, as each party is entitled to have their evidence and claims accepted in the light most favorable to them.

Mootness in Legal Proceedings

Application: Harvard's claims of mootness were rejected as the Court found that the Standing Members maintain a genuine intention to transfer if race-based admissions are altered.

Reasoning: Harvard has not met its burden to demonstrate that the case is moot based on the testimony of Standing Members regarding their willingness to transfer.

Standing in Title VI Claims

Application: The Court affirms that SFFA has associational standing to sue on behalf of its members, including rejected applicants, challenging Harvard's race-conscious admissions.

Reasoning: The Court previously denied Harvard's motion to dismiss for lack of subject matter jurisdiction, affirming that Students for Fair Admissions (SFFA) had associational standing to sue on behalf of its members, which included rejected applicants, particularly Asian American students.

Strict Scrutiny in Race-Conscious Admissions

Application: Harvard must show that its use of race is narrowly tailored to achieve educational diversity benefits, with no effective race-neutral alternatives available.

Reasoning: Strict scrutiny requires a university to show that its purpose is constitutionally permissible, substantial, and that the use of race is necessary for achieving this purpose.

Summary Judgment Standards

Application: The Court denied cross-motions for summary judgment, emphasizing that material factual disputes exist, preventing resolution without a trial.

Reasoning: The Court denied the cross-motions for summary judgment on all counts without prejudice, allowing the parties to reassert their arguments at trial and indicating that the arguments raised in the amicus briefs would also be considered.

Title VI Discrimination in Admissions

Application: The Plaintiff alleges that Harvard's admissions program discriminates against Asian Americans, violating Title VI of the Civil Rights Act of 1964.

Reasoning: Allegations against the Defendant, President and Fellows of Harvard College, claim that its undergraduate admissions program discriminates against Asian Americans, violating Title VI of the Civil Rights Act of 1964.