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Frederick Griffin v. Mississippi Board of Bar Admissions

Citation: Not availableDocket: 2012-CP-00971-SCT

Court: Mississippi Supreme Court; May 16, 2012; Mississippi; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

The case involves an appellant, Frederick Griffin, who has repeatedly failed the Mississippi Bar Exam and is challenging the scoring policies of the Mississippi Board of Bar Admissions. Griffin, having not achieved the required minimum combined score of 132 in both his July 2010 and February 2011 exam attempts, argued that the Board's policies had a discriminatory impact, particularly against minorities, and violated his equal protection and due process rights. His appeal was initially dismissed as moot by the chancery court when he opted to retake the exam. He claimed that the increased passing score requirement and the inability to carry over essay scores had a disparate impact. However, the court determined that Griffin failed to demonstrate purposeful discrimination necessary for an Equal Protection claim, and found the Board's actions rational and legally consistent. The chancery court's decision to uphold the Board's denial of Griffin's petition and score transfer requests was affirmed, and his Motion for Reconsideration was denied. Ultimately, the court concluded that the Board's policies did not violate constitutional rights, and Griffin's claims were without merit.

Legal Issues Addressed

Bar Exam Scoring Requirements

Application: The Mississippi Board of Bar Admissions requires a minimum overall score of 132 to pass the bar exam, without imposing a specific minimum score on the MBE portion.

Reasoning: The Mississippi Board of Bar Admissions requires a minimum score of 132 to pass.

Carrying Over Exam Scores

Application: The Board's policy allows for MBE score carryover but not for essay scores, which was challenged but upheld as not discriminatory.

Reasoning: He claimed that this created a discriminatory effect, especially against those scoring below 132 on the MBE.

Due Process Rights in Exam Scoring

Application: The court found that the Board's review process did not violate due process rights as it was consistent with legal standards and not arbitrary.

Reasoning: The court affirmed that the Board acted rationally within its authority.

Equal Protection Clause and Discriminatory Impact

Application: A claim under the Equal Protection Clause requires proof of purposeful discrimination, which was not demonstrated by the appellant, thereby rendering his claim legally insufficient.

Reasoning: To succeed in an Equal Protection claim, Griffin needed to demonstrate purposeful discrimination, which he failed to do.