# Grutter v. Bollinger The high-water mark of affirmative action in American law. Decided June 23, 2003 by a 5–4 vote, *Grutter v. Bollinger* upheld the University of Michigan Law School's race-conscious admissions program, holding that the educational benefits of diversity are a compelling government interest and that a holistic, individualized review using race as one factor among many is narrowly tailored enough to survive strict scrutiny. It was the first time a majority of the Court — not just a controlling solo opinion — embraced [[Lewis Powell]]'s diversity rationale from [[Regents of the University of California v. Bakke]]. ## The Holding and the Companion Case Justice [[Sandra Day O'Connor]]'s majority opinion drew a sharp line between the law school's permissible holistic review and impermissible mechanical systems. On the same day, in the companion case *Gratz v. Bollinger*, the Court struck down (6–3) Michigan's undergraduate admissions system, which awarded a fixed 20-point bonus to minority applicants — exactly the kind of quota-like mechanism *Bakke* had forbidden. Together the two decisions defined the operative rule for two decades: race may inform an individualized judgment, but it cannot be a formula. O'Connor added a famous time-limit aspiration: "We expect that 25 years from now, the use of racial preferences will no longer be necessary." Justice [[Clarence Thomas]]'s dissent argued the Constitution forbids racial classifications regardless of benign intent — the colorblind position that would become the majority view twenty years later. ## Significance *Grutter* is the doctrinal peak the conservative legal movement spent the next twenty years dismantling. It survived [[Fisher v. Texas I and II]] (2013–2016) in weakened form before being overruled in substance by [[Students for Fair Admissions v. Harvard]] (2023) — which arrived in 2023, almost exactly at the midpoint of O'Connor's 25-year horizon. In the vault's [[Affirmative Action]] arc, *Grutter* is the apex of the diversity rationale's legitimacy and the target around which the entire anti-affirmative-action litigation strategy was organized. ## See Also - [[Regents of the University of California v. Bakke]] — The diversity rationale *Grutter* elevated to majority law - [[Fisher v. Texas I and II]] — Tightened *Grutter*'s strict-scrutiny standard - [[Students for Fair Admissions v. Harvard]] — Overruled *Grutter* in substance - [[Affirmative Action]] — The policy regime at its peak here