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Parents Involved in Community Schools, a Washington Non-Profit Corporation, Plaintiff-Counter-Defendant-Appellant v. Seattle School District, No. 1, a Political Subdivision of the State of Washington Joseph Olchefske, in His Official Capacity as Superintendent Barbara Schaadlamphere, in Her Official Capacity as President of the Board of Directors of Seattle Public Schools Donald Neilson, in His Official Capacity as Vice President of the Board of Directors of Seattle Public Schools Steven Brown Jan Kumasaka Michael Preston Nancy Waldman, in Their Official Capacities as Members of the Board of Directors, Defendants-Counter-Claimants-Appellees
Citation: 285 F.3d 1236Docket: 01-35450
Court: Court of Appeals for the Ninth Circuit; April 26, 2002; Federal Appellate Court
The case involves Parents Involved in Community Schools, a Washington non-profit, appealing against the Seattle School District and several officials regarding the legality of using race in student admissions for oversubscribed high schools in Seattle. The city's demographic shows approximately 70% white residents, while public school demographics reflect about 40% white and 60% non-white students. The distribution of students varies geographically, with a significant concentration of white students living in the northern part of the city, while non-white students predominantly reside in the southern part, where 84% of African-American students and 74% of Asian students are located. The Seattle School District operates ten public high schools, with a notable disparity in quality among them, assessed through standardized test scores, college preparatory course availability, and college attendance rates. The appeal was presented before the Ninth Circuit Court of Appeals, with arguments submitted in December 2001 and a decision filed in April 2002. The case attracted amicus briefs from various civil rights organizations and the American Civil Liberties Union.
The School District has not been legally segregated ("de jure") but faces potential "de facto" segregation due to Seattle's racial diversity and housing patterns. To counter this, the District implemented an open choice assignment plan allowing students to select from ten high schools based on availability, rather than being assigned to their nearest school. This system includes a multi-step process where students rank their preferred schools. If a student is not admitted to their first choice because of oversubscription, the District attempts to assign them to their next choices or ultimately to a school with available space.
In the 2000-01 academic year, five high schools were oversubscribed, with about 82% of students selecting these schools as their first choice, highlighting the issue of oversubscription. To manage this, the District employs four tiebreakers for admissions. The first gives preference to students with siblings at the requested school, accounting for 15-20% of assignments. If oversubscription persists, the second tiebreaker, which is race-based, is applied to promote racial balance. Students' races are identified through registration materials, with visual inspections used when parents decline to specify. This racial tiebreaker is key to the lawsuit, as it aims to align the school's racial demographic with Seattle's overall student population (40% white and 60% non-white). Schools that deviate from this ratio are termed "integration positive," and students whose race helps achieve balance are given admission preference. Once a school reaches balance, the racial tiebreaker is no longer applied. This racial factor influences about 10% of high school assignments. Remaining seats after this process are filled using a distance-based tiebreaker, favoring applicants who live closest to the school.
A lottery tiebreaker is infrequently used in high school admissions due to precise distance calculations. The group Parents Involved in Community Schools (the "Parents") consists of parents whose children faced denial of admission to preferred high schools based on race. They highlight two members, Jill Kurfurst and Winnie Bachwitz, whose children applied to Ballard, Roosevelt, and Nathan Hale High Schools but were denied admission to Ballard due to the racial tiebreaker, despite being accepted into its Biotech Academy. Both were also denied admission to Nathan Hale and assigned to Ingraham High School, which posed significant commuting challenges, requiring over four hours of travel each day without school bus service. After their appeals were unsuccessful, the families opted for private schooling. Two additional members, Rick Hack and John Miller, have children in middle school who may be similarly affected by the racial tiebreaker.
In July 2000, the Parents initiated legal action against the School District, claiming that the racial tiebreaker violates state and federal laws, including the Washington Civil Rights Act and the Equal Protection Clause of the Fourteenth Amendment. Both parties sought summary judgment, and the court ruled in favor of the School District, upholding the racial tiebreaker. In its April 6, 2001 opinion, the district court interpreted the Washington Civil Rights Act in a manner consistent with constitutional requirements for equal educational opportunities, concluding that prohibiting the School District's integration plan would be unconstitutional.
The district court applied strict scrutiny to evaluate the School District's admissions plan, concluding that achieving racial diversity and addressing de facto residential segregation are compelling government interests. The court determined that the assignment plan was narrowly tailored to meet these interests and ruled in favor of the School District. The Parents subsequently appealed, arguing that the racial tiebreaker employed by the School District violates Washington Revised Code section 49.60.400, which prohibits discrimination or preferential treatment based on race in public employment, education, and contracting. The section is applicable to the School District, as defined within the law.
As Washington courts have not yet interpreted this provision, the federal court is tasked with predicting how the Washington Supreme Court would interpret it, applying general rules of statutory construction. The court emphasized that if the language of an initiative is clear and unambiguous, it should not be subject to judicial interpretation, and the inquiry should end there. The debate over legislative history regarding section 49.60.400 is unnecessary, as the text is straightforward. Additionally, the interpretation of voter initiatives differs slightly from legislative statutes in that it should be understood from the perspective of an average informed lay voter. The plain meaning of section 49.60.400 is evident in its application to the School District's use of the racial tiebreaker.
The provision in question prohibits the School District from discriminating or granting preferential treatment based on race in public education, as outlined in Wash. Rev. Code 49.60.400(1). The term "preferential" is defined as providing advantage or preference, which, in a competitive admission context, means that the racial tiebreaker gives an advantage to certain racial groups over others based solely on race. This is evident in the admissions process to oversubscribed high schools, where students are selected based on their race to achieve a "racially balanced" student body, contradicting the prohibitions of section 49.60.400. The practice favors nonwhite students at Ballard and white students at Franklin based on their race, confirming that the tiebreaker grants preferential treatment. The district court acknowledged that this could be seen as granting a "preference" in common terms but was concerned that applying section 49.60.400 to disallow the tiebreaker might conflict with the Washington Constitution. To address this, the court adopted a "saving construction" that upheld the School District's admissions plan, despite the unnecessary nature of this approach. It was argued that both Washington and federal law would support the interpretation that prohibits the racial tiebreaker. Furthermore, the Washington Constitution mandates equal educational provision without racial distinctions or preferences, reinforcing the view that the tiebreaker violates the stated law.
The district court affirmed that the Washington Constitution permits school districts to use race-based classifications to promote racial diversity and address de facto segregation. In *State ex rel. Citizens Against Mandatory Bussing v. Brooks*, the Washington Supreme Court supported a trial court's decision against recalling board members over their busing plan aimed at remedying segregation, citing *Swann v. Charlotte-Mecklenburg Board of Education* as establishing broad authority for school authorities to implement educational policies that reflect community diversity. The court determined that if the Constitution allows for mandatory busing in a dual 'de jure' system, it similarly applies in a dual 'de facto' system, thus validating the board's discretion in such matters. Subsequent case law, including *Citizens Against Mandatory Bussing v. Palmason*, reinforced the notion that school boards possess the authority to adopt busing plans without being hindered by claims of fundamental rights that do not abrogate their powers. The court emphasized that while the board must act in the majority's interest, it is not legally obligated to eliminate de facto segregation. The district court concluded that any amendment to restrict the authority to provide racially integrated schools would be unconstitutional, as the Washington Constitution does not mandate racially diverse schools. However, the court's reasoning was deemed flawed, as there is no constitutional requirement for the School District to ensure racial diversity.
The Washington Constitution grants school districts the permissive authority to adopt racial diversity programs but does not mandate such measures. School districts must not use this authority in ways not authorized by law. Washington Revised Code section 49.60.400 recently prohibits the School District from using a racial tiebreaker for achieving racial diversity, thus affirming that this statute does not violate the Constitution. The U.S. Constitution allows for rare race-based preferences, but this does not prevent the state from imposing restrictions. Precedents indicate that section 49.60.400 effectively limits the School District's constitutional obligations to educate students.
The district court referenced federal law, particularly the case Coalition for Economic Equity v. Wilson, which upheld California's Proposition 209. This case concluded that Proposition 209 did not restructure the political process impermissibly and did not violate individual rights to equal treatment. It clarified that Proposition 209 does not preclude voluntary desegregation efforts, which are viewed as a "deck shuffle" rather than a "stacked deck." However, the district court incorrectly generalized this interpretation to suggest that section 49.60.400 does not apply to any programs aimed at addressing racial imbalances. The Coalition decision specifically stated that while Proposition 209 did not invalidate certain voluntary desegregation programs, it did not guarantee that all voluntary programs would be exempt from its reach.
The School District's racial tiebreaker operates differently from the voluntary desegregation plan in Seattle, which utilized busing and reassignment strategies that did not disadvantage any group. Instead, the Seattle plan aimed to create balanced demographics by integrating schools through specific attendance zones without solely relying on race. In contrast, the School District's approach may not align with these principles, thus making its implementation of race-based measures potentially problematic under the new law.
The plan in Seattle did not base admissions decisions solely on race, contrasting with the racial tiebreaker currently under scrutiny, which does. This racial tiebreaker is deemed inherently discriminatory. The application of section 49.60.400 to the School District’s use of this tiebreaker is consistent with previous rulings, deeming it illegal. The district court overlooked the pivotal Supreme Court case, Regents of the University of California v. Bakke, which addresses racial classifications in admissions. Justice Powell's plurality opinion in Bakke, reaffirmed as controlling law in this Circuit, concludes that the admissions program, which reserved seats for minority students, constituted a racial classification. Bakke, a white applicant denied admission, argued that this preference violated Title VI and the Equal Protection Clause. Powell emphasized that equal protection cannot vary based on race and that the Fourteenth Amendment was framed in universal terms, rejecting distinctions based solely on ancestry. He criticized the admissions program's "two-class theory," noting that the white majority encompasses various minority groups with histories of discrimination. Powell ultimately stated that any admissions preference based solely on race or ethnic origin is fundamentally discriminatory and must be rejected as invalid.
The School District's use of a racial tiebreaker in admissions effectively categorizes Seattle public high school students as either white or nonwhite, disadvantaging students from the racial majority at integration-positive schools by excluding them from a set number of seats. This practice is deemed a racial classification that grants preference based on skin color, similar to the admissions program challenged in Bakke, and is found to violate Washington law. The analysis emphasizes that the state's policy, which prohibits discrimination based on race, color, or ethnicity, reflects the collective decision of Washington citizens to reject such preferential treatment, even if it aims to promote racial diversity in schools. Although the School District's intentions to foster diversity are recognized, the court underscores that the cost of this diversity—denying students access based solely on race—is deemed excessive. The district court acknowledged the preference aspect of the tiebreaker but expressed concerns about potential conflicts with the Washington Constitution, leading to a "saving construction" that upheld the School District's plan. However, this construction is critiqued as unnecessary, as both Washington and federal law support the interpretation that prohibits the racial tiebreaker. The Washington Constitution underscores the state's duty to provide education without racial distinctions, reinforcing the argument against the School District's practices.
The Washington Supreme Court has established that the Washington Constitution permits school districts to use race-based classifications to promote racial diversity and address de facto segregation. In the case of *State ex rel. Citizens Against Mandatory Bussing v. Brooks*, the Court upheld a trial court's decision preventing the recall of board members who planned to implement a busing strategy aimed at remedying de facto segregation. The Court referenced *Swann v. Charlotte-Mecklenburg Board of Education*, asserting that school authorities possess broad discretion to create educational policies, including establishing student ratios that reflect district demographics. Consequently, the Court affirmed that court-directed busing for desegregation in a dual de facto system falls within the discretion of school authorities, thus allowing the board members' actions to go unchallenged by plaintiffs alleging malfeasance.
Furthermore, in the subsequent case of *Citizens Against Mandatory Bussing v. Palmason*, the Court reaffirmed the school district's authority to implement mandatory busing in Seattle to address de facto segregation. The plaintiffs did not contest the board's authority to enact the plan, and the Court clarified that the board was obligated to act in the best interests of the majority of students, regardless of any adverse effects on some individuals. The Court concluded that while the school district was not mandated to eliminate de facto segregation, pursuing racial diversity was a legitimate and sound policy for the educational system.
The school board's method of desegregation was a valid exercise of its discretionary powers, as the plaintiffs failed to demonstrate that the plan was illegal. The directors faced the challenge of balancing the benefits of the neighborhood school concept against those of an integrated school system. They determined that modifying the existing system best fulfilled their duty to provide equal educational opportunities for all children.
The district court concluded that the Washington Constitution allows for racially integrated schools, asserting that any initiative amending this authority would be unconstitutional. However, the court's reasoning is flawed; the Washington Constitution permits, but does not mandate, the provision of racially diverse schools. School districts can only exercise this permissive authority in ways authorized by law. A recent law, Washington Revised Code section 49.60.400, prohibits the School District from using a racial tiebreaker to promote racial diversity, meaning this law does not violate the Washington Constitution.
Additionally, the district court relied on federal law, particularly the decision in Coalition for Economic Equity v. Wilson, which addressed the validity of California's Proposition 209, similar to Initiative 200. The court found that Proposition 209 did not restructure the political process in an unconstitutional manner and did not infringe upon individuals' rights to equal treatment.
Prop. 209 does not prohibit voluntary school desegregation efforts, such as the busing program discussed in Seattle, which is deemed a "deck shuffle" rather than a "stacked deck" program. The district court interpreted the Coalition case to mean that Prop. 209 only upholds voluntary desegregation efforts, concluding that section 49.60.400 does not apply to programs aimed at addressing racially imbalanced schools. However, this interpretation is disputed; Coalition merely stated that Prop. 209 does not invalidate certain voluntary desegregation programs without ruling out the potential invalidation of other, differently structured programs. The Seattle plan utilized non-racial criteria for student assignments and aimed to desegregate through pairing and triading attendance areas, resulting in balanced reassignments. In contrast, the racial tiebreaker in question operates solely on race during admissions, rendering it "inherently invidious" and thus falling under the restrictions of section 49.60.400. This conclusion aligns with the Coalition decision. Moreover, the district court neglected to reference the pivotal Supreme Court case Regents of the University of California v. Bakke, which addresses racial classifications in educational admissions.
Justice Powell's opinion in Bakke is established as controlling law in this Circuit, supporting the interpretation of section 49.60.400. The Bakke case involved the University of California at Davis Medical School's admission program, which reserved seats for minority students. Allan Bakke, a white male denied admission, argued that this program violated Title VI and the Equal Protection Clause. Powell's plurality opinion recognized the program as a racial classification, limiting white applicants to compete only for remaining seats after minority preferences were applied. He asserted that the principle of equal protection must apply universally, rejecting distinctions based on race or ethnicity as fundamentally incompatible with equality. Powell condemned the program's implicit "two-class theory," emphasizing that the white majority comprises various minority groups with their own histories of discrimination. He determined that any admissions policy favoring a group solely based on race or ethnicity is facially invalid. Similarly, the Seattle School District's use of a racial tiebreaker categorizes students into white and nonwhite groups, reflecting the same problematic approach identified in Bakke.
Integration-positive schools restrict admission for students of a racial majority by implementing a fixed number of available seats, a practice considered a racial classification based solely on skin color. This approach resembles the classification scrutinized in the Bakke case and is characterized as a preference. The court emphasizes that once a dual school system is dismantled, states cannot assign students based on race. Consequently, the use of a racial tiebreaker by the School District is found to violate Washington law. Although the School District aims to promote racial diversity for the benefit of all students, Washington citizens have determined that achieving such diversity through racial discrimination is unacceptable. The court maintains that it is not tasked with evaluating competing policy merits but rather with adhering to the people's choice as expressed in state law, specifically under Wash. Rev. Code 49.60.400, which prohibits preferential treatment based on race. The court concludes that the racial tiebreaker constitutes unlawful preferential treatment, aligning with both Washington law and federal legal principles. Therefore, the district court's decision is reversed.
A specialized learning program integrates science, mathematics, and language arts to prepare students for advanced study in biosciences, with its own admissions process and prerequisite classes. Admission to this program does not guarantee entrance to Ballard High School, which follows an open enrollment policy. Oversubscription of schools is not geographically based, with both oversubscribed and undersubscribed schools located in various areas. A racial balance is maintained with an acceptable deviation set at 15%, allowing a school’s student body to consist of 25% to 55% white students. Currently, three of the five oversubscribed schools, including Ballard, use a racial tiebreaker for admissions, applicable only for incoming ninth graders, not for transfers in later grades.
The Washington Constitution grants voter initiatives legislative power, equating their status to that of enacted laws, although they cannot amend the Constitution. The School District revised its admissions plan during litigation to alleviate student hardships, increasing the acceptable deviation from 10% to 15% and limiting the application of the racial tiebreaker to freshmen. Parents argued that both the original and revised plans violated state and federal law. Neither party sought to certify a question to the Washington Supreme Court, and the court found the legal interpretation under Washington law to be clear, choosing not to exercise certification discretion. This interpretation differs from legislative statute interpretation.
Washington courts interpret statutory terms with established legal meanings based on common law, presuming that the legislature intended to maintain these meanings when definitions are absent. The statute in question could imply that the School District's racial tiebreaker may constitute discrimination against students based on race, as discrimination involves making distinctions without regard to individual merit. While courts typically avoid attributing the same meaning to different statutory terms, they recognize that overlap can occur, especially in cases involving disjunctive terms.
The School District's use of the tiebreaker involves granting a race-based preference, though the court does not need to determine if it also constitutes race-based discrimination. The district court's view that the tiebreaker is not a preference was influenced by the notion that the program impacts both white and non-white students equally, promoting racial integration. However, this perspective overlooks the fundamental issues associated with racial distinctions, which are inherently problematic and can lead to stigma and hostility, as noted by the U.S. Supreme Court. Ultimately, the argument that the tiebreaker does not create a preference fails to address the deeper implications of racial classifications in educational policies.
The excerpt addresses the interpretation of equal protection under the law, emphasizing that it should consistently apply to individuals regardless of race. It criticizes the district court for not adequately construing the relevant statute, which mandates that if any part conflicts with federal or state constitutions, it should be implemented only to the extent allowed by those higher laws. The discussion highlights the semantic similarities between "remedying de facto segregation" and "achieving racial diversity," suggesting that failure to address racially concentrated housing leads to racially imbalanced schools. The excerpt also critiques the district court's reliance on the Dawson v. Troxel case, arguing that it was misapplied. It clarifies that the cited cases do not support a requirement for schools to achieve racial balance in the absence of prior de jure segregation, and emphasizes that the context of these cases is crucial for understanding their implications regarding the use of racial criteria in educational institutions.
The court determines that an intermediate appellate court decision is not controlling due to its inconsistency with Washington Supreme Court rulings. Federal law does not govern this state law issue, and the district court acknowledged that, despite the overlap of federal and state laws regarding racial preferences and discrimination, federal cases serve as persuasive authority for interpreting Washington's section 49.60.400. The Washington Supreme Court has previously indicated that state courts may reference federal law interpretations when construing related state statutes.
The discussion references Proposition 209, which prohibits discrimination or preferential treatment based on race or other characteristics in public employment and education. A concurrence argues that reliance on federal law, specifically Bakke, is limited to instances where state and federal statutory texts are nearly identical. However, the court disagrees with this narrow interpretation, asserting that section 49.60.400(1) shares substantial similarity with the statute examined in Bakke, which addressed the Equal Protection Clause in conjunction with federal anti-discrimination law. The court emphasizes that both federal and state provisions aim to prevent discrimination based on race, thus justifying the use of federal case law for state law analysis.
Cases interpreting various federal statutes can provide insights into the interpretation of a specific Washington statute, not due to identical language but because both federal and state statutes aim to combat discrimination. Justice Powell's remarks in Bakke regarding discrimination under 42 U.S.C. § 2000d are pertinent to understanding the term "preference" in Washington Revised Code § 49.60.400(1), particularly in light of this Court's commitment to that opinion. The Seattle School District's use of a racial tiebreaker for student admissions operates differently from the Bakke program, where reserved seats are predetermined. However, both approaches effectively exclude "majority" students, whether at the start or the end of the admissions process.
Circuit Judge Graber concurs, emphasizing that the Seattle School District's racial tiebreaker grants preferential treatment based on race, violating Initiative 200, codified as Wash. Rev. Code § 49.60.400. Neither the U.S. Constitution nor the Washington Constitution prohibits such laws, nor is there a constitutional requirement for a racial tiebreaker in the absence of de jure school segregation. Any existing segregation in Seattle's high schools stems from residential patterns.
Graber critiques the majority's reliance on federal law for interpreting Initiative 200, arguing that the Washington Supreme Court would not look to federal law in this context and that the majority misinterprets federal precedent. The Washington Supreme Court typically only references federal law when state and federal statutes are similarly worded, and the relevant part of Initiative 200 lacks a federal counterpart. This principle traces back to Black Ball Freight Service, Inc. v. Washington Utilities and Transportation Commission, which addressed motor carrier regulations.
The amended state statute closely aligns with the federal statute governing permits issued by the Interstate Commerce Commission for interstate motor carrier applicants. The court considered relevant federal case law as persuasive due to the textual similarities between federal and state laws. Notable cases include *Drinkwitz v. Alliant Techsystems, Inc.* and *Inland Empire Distribution Sys., Inc. v. Utils. Transp. Comm'n*, where the Washington Supreme Court emphasized the persuasive nature of federal interpretations, despite federal authority not being controlling in state law matters.
The court reiterated this principle in *Bravo v. Dolsen Cos.*, which involved labor law and the definition of "concerted activity." It acknowledged that while federal interpretations can guide state statutes with similar language, they are not binding. This approach extends to anti-discrimination law, as seen in *Roberts v. Atlantic Richfield Co.*, where the court looked to federal cases after noting the similarity of statutory provisions.
In *Farnam v. CRISTA Ministries*, the Washington Supreme Court explicitly applied the requirement of textual similarity when interpreting RCW 49.60 against Title VII of the Civil Rights Act of 1964. The court quoted the federal statute before considering relevant federal interpretations. The case *Marquis v. City of Spokane* is significant as it addressed whether the anti-discrimination provisions of RCW 49.60 apply to independent contractors. The court acknowledged looking to federal law for guidance but ultimately rejected reliance on federal cases due to notable differences in statutory language and the absence of a provision in Title VII that mirrors specific state provisions requiring liberal construction to achieve the act's purposes.
Federal interpretations of Title VII do not guide the understanding of RCW 49.60.030(1) due to significant differences between state and federal laws. Washington courts limit reliance on federal anti-discrimination case law to situations where the statutes are identical or substantially similar, which is not the case with Initiative 200 (I-200). Furthermore, the premise for interpreting voter initiatives differs from legislative statutes; the text is understood based on what an average informed lay voter would interpret, rather than through the lens of federal law.
The majority's use of Regents of University of California v. Bakke as a basis for claiming that a racial tiebreaker is a preference violating I-200 is flawed. The majority misinterprets Justice Powell's opinion, which did not categorically deem all racial preferences impermissible; rather, it evaluated them based on context and purpose. In contrast, the assessment of the school district's assignment plan straightforwardly identifies it as granting preferential treatment based on race, which is a direct violation of I-200's plain language. Additionally, suggesting that federal law prohibits all racial classifications in educational admissions contradicts Bakke and Ninth Circuit rulings.
Justice Powell's opinion in Bakke determined that not all racial preferences are impermissible; rather, some are unlawful depending on their purposes. The University of California's admissions policy was found to violate federal law, but Powell acknowledged that race-conscious policies aimed at achieving a diverse student body are constitutionally acceptable. He noted that race could be a "plus" in admissions as long as it does not prevent individual comparison among candidates. The state has a legitimate interest in considering race and ethnicity in admissions. This court has affirmed that race can be considered in admissions for reasons beyond remediation, such as educational diversity, which satisfies strict scrutiny standards.
The district court's decision to deny Smith's summary judgment was based on the understanding that race could be a factor in admissions decisions, consistent with Bakke. The court also established that achieving diversity and addressing past discrimination are not the sole justifications for racial classifications under federal law. The court recognized California's compelling interest in enhancing education quality in urban schools.
Additionally, the majority's claim that the school district's assignment plan is impermissible due to similarities with Bakke's admissions policy oversimplifies Powell's analysis. The permissibility of a racial classification depends on both its form and the purposes it serves, and any racial classification must be the most narrowly tailored method to achieve a compelling government interest. The majority's critique of the district court's reliance on federal law to interpret state statute I-200 is acknowledged, but the concurrence emphasizes that the interpretation's accuracy is not the focus of their review.
The court has granted the Appellant's motion for an injunction, prohibiting the Appellees from using a racial tiebreaker for high school assignments until further notice. The request for immediate issuance of the mandate has been denied. The relevant state law, I-200, prohibits discrimination or preferential treatment based on race, sex, color, ethnicity, or national origin in public employment, education, or contracting. The court clarified that it does not need to decide whether federal constitutional law forbids the use of a racial tiebreaker, as state law alone renders it impermissible. The court emphasized its preference to resolve issues based on state law first, in line with established judicial principles. Additionally, the interpretation of I-200 is distinct from federal law, imposing stricter limitations on the consideration of race in school admissions decisions.