Meredith v. Jefferson County Board of Education (2006)
- Docket
- 05-915
- Decided
- 2006-01-01
Summary
Question: 1) Do Grutter v. Bollinger and Gratz v. Bollinger allow a school district to use race as the sole factor to assign high school students to public schools? 2) Can a student enrollment plan that requires each school's student population to be between 15% and 50% African-American meet the Fourteenth Amendment's requirement that racial classifications be narrowly tailored to a compelling government interest? Conclusion: No and no. By a 5-4 vote, the Court applied a "strict scrutiny" framework and found Jefferson County's enrollment plan unconstitutional under the Equal Protection Clause of the Fourteenth Amendment. Chief Justice John Roberts wrote in the plurality opinion that "The way to stop discrimination on the basis of race is to stop discriminating on the basis of race." The Court acknowledged that it had previously held that racial diversity can be a compelling government interest in university admissions, but it ruled that "[t]he present cases are not governed by Grutter ." Unlike the cases pertaining to higher education, Jefferson County's plan involved no individualized consideration of students, and it employed a very limited notion of diversity ("black" and "other"). Jefferson County's goal of preventing racial imbalance did not meet the Court's standards for a constitutionally legitimate use of race: "Racial balancing is not transformed from 'patently unconstitutional' to a compelling state interest simply by relabeling it 'racial diversity.'" The plans also lacked the narrow tailoring that is necessary for race-conscious programs. The Court held that Jefferson County's enrollment plan was actually targeted toward demographic goals and not toward any demonstrable educational benefit from racial diversity. Jefferson County also failed to show that its objectives could not have been met with non-race-conscious means. In a separate opinion concurring in the judgment, Justice Kennedy agreed that Jefferson County's use of race was unconstitutional but stressed that public schools may sometimes consider race to ensure equal educational opportunity.