I. Civil Rights Act and Affirmative Action
On July 2nd, 1964, the Civil Right Act was passed; all form of segregation and discrimination against African American were abolished. African American has been acknowledged as an equal race compared to other races (History, 2010). The seven protected classes including race, color, national origin, sex, religion, disability, and age were formed (Cummins, 2017).
In pursue of stimulating the racial integration in school and workplace, affirmative action was established. With affirmative action, some schools or universities provide privileges to specific race such as African-American and Hispanic aiming to help them excel their education and provide diversity as well as equality in school. However, according to BLACK, WHITE AND GREY: LAW AND ETHICS IN BUSINESS, it states that:
The fundamental problem with acting “affirmatively”—which means specifically pursuing members of an underrepresented protected class for either admission to school or employment—is that it does exactly the opposite of what equal protection demands: it uses race, gender, or any other protected class status to differentiate candidates (Cummins, 2017).
The statement implies that instead of accelerating racial integration, affirmative action has hurt other races and destroyed the equal protection clause.
Races such as White and Asian-American have been hurt by affirmative action. A lot of lawsuits have been brought up to challenge that. The first successful lawsuit that was brought up to the supreme court and got the affirmative action reversed was Regents of the University of California v. Bakke in 1978, followed by United Steelworkers v. Weber in 1979 (Cummins, 2017). In 2003, the landmark case, Grutter v. Bollinger was raised. The supreme court claimed that undergraduate program could not use different “points” to award people from different races in admission decision; albeit, they could consider race in law school, but it can’t be a dispositive factor (Cummins, 2017). In the decision, Justice O’Connor wrote that “The Court expects that 25 years from now, the use of racial preferences will no longer be necessary to further the interest approved today” (Cornell University Law School, 2003).
Notably, in 2014, the group of Asian-Americans filed a lawsuit against Harvard University in federal district court claiming that the university discriminate against them racially and ethnically (Hartocollis, 2018). In the lawsuit, STUDENT FOR FAIR ADMISSION, INC. acts on behalf of Asian-Americans or the plaintiff and PRESIDENT AND FELLOWS OF HARVARD COLLEGE (HARVARD CORPORATION); and THE HONORABLE AND REVEREND THE BOARD OF OVERSEERS are the defendant (2014).
II. Key Facts
In 2015, Asian-Americans make up 5.28% of the total population in the United States (United States Census Bureau, n.d.). Interestingly, the number of them holding college degree is significantly high compared to other races. 60.4% of Asian-Americans have associate degree; 53.9% has bachelor’s degree and 21.4% of them has advance degree (Ryan and Kurt, 2016).
Not only that a lot of Asian-Americans hold college degree or advance degree, but this race also outperforms other races when it comes to taking standardize test like SAT. In 2016, 12% of the SAT test takers were Asian-Americans (College Board, 2016). Their average score on critical reading is 529 which is one score higher than the average score of the White and 99 scores higher than the average score of the African-Americans. As for Mathematic, the average for Asian-Americans is 602 which is 69 points higher than the average score of the White, and 177 scores higher than the average of the African-Americans. Asian-Americans also outperform other races in writing as well (College Board, 2016). From this data, we can see that based on academic performance alone, Asian-Americans outperform other races. This would indeed help them getting the admission from the university easily especially the ivy league university that requires high academic performance. In the University of California Berkeley, Asian-Americans make up approximately 42% of the students on the campus in 2015, 2016, and 2017 (UC Berkeley, 2018) and this is because UC Berkeley does not take race into consideration when accepting the students to study, “the University of California system does not advantage or disadvantage certain applicants based on their race. Such practices across all college systems are unconstitutional” (Los Angeles Time, 2015). The same goes to California Institute of Technology, Asian-American makes up 43% of the total undergraduate students (Caltech, 2018).
The research studies from Princeton’s Office of Population found out that by eliminating affirmative action, the number of African-Americans who get permitted to study in the universities would fall from 33.7% to 12.2% and the number of Hispanic applicants who get the acceptance would fall from 26.8% to 12.9% (Brown, 2005). The number of Asian-American; however, rises significantly from 23.7% to 31.5%, whereas the number of White applicants only have a slight change. This implies that without taking race into consideration, many African-Americans and Hispanics would not be able to get into the ivy league schools. The university would be dominated by Asian-Americans and Caucasians which is then making the university campus less diversified.
But does the university really need to take race into consideration? What are the roles of the university and is providing diversity on campus more important than accepting qualified students? Will every race have equal opportunities of getting accepted to the university?
Back in 1920s, Harvard University was notorious for being discriminating against Jewish people. In 1918, 20% of the freshmen in Harvard University were Jewish. Being afraid that other families would choose other elite universities than their university, Lawrence Lowell, the President of Harvard University, decided to put a cap on the next enrollment of Jewish students. The faculty members of the universities agreed and in 1922, race and color, religious preferences, maiden name of mother, and birthplace of father were asked on the application. However, in 1923, the Committee on Methods of Sifting Candidates for Admission turned down the cap for Jewish people; as the result, in 1925, the number of Jewish people that got accepted was 27.6%. Though committee overturned Harvard’s proposal of having a cap, it advised the university to look at other approaches such as limit the number of students accepted for the upcoming academic year to 1000 students or not having a standardize way to decide on the applicant admission. The university adopted the non-standardized way in admission decision; the result was shocking because the number of Jewish accepted to school dropped from 27.6% to 15% (STUDENTS FOR FAIR ADMISSIONS, INC., v. Harvard).
Not only that Harvard discriminated against Jewish people, but the university seems to discriminate against Asian-American as well. The data from Washington Post shows that since 1992, the acceptance rate of Asian-American to Harvard university has been stagnant even though Asian-American applicants has been rising dramatically (Blum, 2017). In between 1980 and 1990s, Asian-American applied to Harvard University was 28, 754 which is approximately 23.1% of the overall application. However, the acceptance rate for this race is only 20.9% which is 17.8% lower than the acceptance rate for African-American, the race that makes up only 5.3% of the overall applicants. Hispanic also has higher acceptance rate, 31.6% even though its applicants make up only 5.6% of the total applicants (Espenshade, et al, 2004). In 1992, 2003, and 2017, the acceptance rate for Asian-American in Harvard university is 19%, 18% and 22.2% respectively (Espenshade, et al, 2004) (Admission Statistic, n.d.). This data demonstrates that there is a quota for Asian-American because even though they perform well on SAT and has a significant increase in the number of applicants, the acceptance rate is still stagnant.
Interviewed by CNN, Vijay Jojo Chokal-Ingam, the author of the book “Almost Black: The True Story of How I Got Into Medical School by Pretending to Be Black” mentioned that he was able to go to medical school because he lied about his race. He disguised himself as black and went to black association. Having only 3.1 GPA, Vijay got accepted into Saint Louis University, the University that has the average of 3.7 GPA under minority privilege category (CNN, 2017).
The numerical data and Vijay’s story depicts that race plays a significant role in applying to the university. Merit or academic performance tend to be less essential as the school favor diversity and prioritize or favor races like African-American and Hispanic over Asian-American and White. Affirmative action that has been used to promote integration indeed help the so-called non-privilege race like African-American and Hispanic to get into the university, yet hurt other races like Asian-American and cause discriminate against them.
III. Legal Issues Bring to The Court
As mentioned above, in 2014, the ivy league school, Harvard University was sued by a group of Asian-American students under title VI of the Civil Right Acts. In the complaint, they point out four aspects to support their claim on how Harvard violates the Civil Right Acts. Firstly, Harvard University uses racial classification to make the decision on the application. They use this technique to discriminate against Asian-American just as when they discriminated against Jewish people. Secondly, Harvard engage in racial balancing or quota meaning that regardless of the amount of applications, the number of Asian-American accepted to study in the university would be the same. Thirdly, Harvard fails to explain how it uses race as its “plus factor” in admission decision. As the data shows, Asian-American have higher achievement than other races academically and socially. With perfect GPA, high extra-curriculum, and experience, Asian-American should have accepted in the school, but the acceptance rate of Asian-American is stagnant and Harvard fails to stipulate the reasons. Last but not least, Harvard uses racial preferences to achieve diversity rather than using race-neutral.
IV. Harvard University and Its Response
Harvard University has denied the complaint. It states that the university has never used quota or never been discriminated on the ground of race. It asserts that race is just only a small part of it. The university uses holistic admission and critical mass diversity objective to support their claim.
This ivy league university affirms that rather than solely look at academic background or merit, the school looks at the characteristic, personality and the promise that demonstrate the passion and the willingness of the students toward obtaining the education (STUDENTS FOR FAIR ADMISSIONS, INC., v. Harvard, 2014). From the school website on the “What We Look For”, it depicts clearly that the school takes a close look on growth and potential, interests and activities, and how the applicants contribute to the university (Harvard, n.d.). On top of that, Harvard responded to the Federal District Complaint by showing the increase of the admitted Asian-American students in the school. In the previous academic year, the school admitted only 17.6%, whereas the admitted class for 2021 rises to 22.2% (Iuliano, 2014). Therefore, claiming that Harvard University discriminates Asian-American on the ground of race is false because the school uses holistic admission to make admission decision which is legitimately subjective. On top of that, there is no exact evidence to prove that the school uses quota to limit the number of Asian-American student.
Besides using holistic admission, Harvard also raise the importance of studying in diversified environment as well. It asserts that with diversified background in class, students learn more and gain more experience. Robert Luliano, the General Counsel in Harvard University, responded to the complaint by emphasizing the vitality of diversity through
“It encourages students to question their own assumptions, to test received truths, and to appreciate the spectacular complexity of the modern world. This larger understanding prepares graduates to be active and engaged citizens wrestling with the pressing challenges of the day, to pursue innovation in every field of discovery, to make positive economic contributions and to expand humanity’s learning and accomplishment” (2014).
V. Legal Concepts and Other Cases Relevant to Harvard Lawsuit
Drafted, finalized and enacted by the founding father of the United States, the fourteenth amendment was passed in July 13th, 1866 (National Constitute Center, n.d.). The first section of the amendment states precisely that “No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws” (National Constitute Center, n.d.). As demonstrated, the first section of the amendment addresses three aspects. The first one is the citizenship clause. The clause makes it clear that everyone that is born or naturalized in the United States will be granted a citizenship. The second clause is the due process clause. Under the due process clause, the citizen’s life, liberty and property will not be denied by the states. The last one is the equal protection clause. Equal protection clause ensures that every citizen in the United States is treated the same way; the minority group will not get different treatment from the majority group. Though the law is there to protect each citizen and to provide equal protection to all of them, it does not mean that discrimination and racism could be combat completely. In Brown v. Board of Education, the case which an African-American girl needed to walk far to go to school because the school nearby her house was for white only, the judge ruled in favor of Brown struct down the “separate but equal” doctrine. Chief Justice Earl Warren made her decision by emphasizing that separate education violated the equal protection clause under the fourteenth amendment (Oyez, n.d.).
To strengthen equal protection and eliminate discrimination, the Civil Right Act was created. Title VI of the Civil Right Act protects people regardless of race, age, gender and national origin from being discriminated in the activities or program under federal fund (Findlaw, n.d.). It elucidates that
“No person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance” (Findlaw, n.d.).
Therefore, state schools that receive funds from the federal government are under the protection of the Civil Right Acts. Even after racism and segregation (Brown v. Board of Education) were abolished in educational sector through the Civil Right Act, the number of African-American students in higher education was still low. In 1965, there were only 5% of African-American in undergraduate program in which 1% of them were in law school, and 2% medical school (Bautsch and Suzanne, 2014). As the result, in the same year, President Lyndon Johnson enforced both public and private entities that were under the government control to use affirmative action by signing the executive order (Bautsch and Suzanne, 2014). Affirmative action is defined as the admission policies that are used to provide equal access to education for every group of students regardless of race, gender, creed or national origin. It focuses on enhancing the opportunities to access to education for African-American or any other underprivilege students (Bautsch and Suzanne, 2014).
However, under affirmative action, some students from different race like White and Asian-American have been at disadvantage. In University of California v. Bakke case, a 30 years-old white man was denied the admission to medical school even though his academic performance was better than the qualified student of the African-American race. The reason why the school rejected him was because they protected 16 slots for the African-American. The judge ruled that affirmative action can be used in college admission, but racial quota is unconstitutional as it contravene the Civil Right Act (Oyez, n.d.).
As for Fisher v. University of Texas case, the case was about a Caucasian girl sued University of Texas on the ground of violating the Civil Right Acts title VI and the equal protection clause of the 14th amendment, the judge ruled in favor of the University of Texas under strict scrutiny. This means that the reasons why the university won the case because it has the compelling interest of the government which in this case the diversity on campus. Albeit, Justice Clarence Thomas asserted that “there is nothing “necessary” about the benefits that flow from racial diversity in higher education, so there in no compelling state interest to promote it” (Oyez, n.d.).
As for Meredith v. Jefferson, the case is about parents, Meredith, suing Jefferson County Public School on behalf of her son as the school rejected his application. The case was appealed to the supreme court on the ground of violating the equal protection and the Title VI of the Civil Right Acts. The evidence to support the complaint was that the school set the maximum number of African-American students to no more than 50% of the total students in school. However, the judge ruled in favor of the school by proclaiming that racial diversity in K-12 public school is important, and it compels to the interest of the government which mean the case passes strict scrutiny (Oyez, n.d.). Chief Justice John Roberts said that “The way to stop discrimination on the basis of race is to stop discriminating on the basis of race” (Cornell Law School, 2008). On the other hand, Justice Anthony Kennedy didn’t agree with Roberts and other justices. He said “Diversity, depending on its meaning and definition, is a compelling educational goal a school district may pursue” (Cornell Law School, 2008).
VI. Conclusion for Harvard University Case
Based on the three cases above, one can see clearly that some people are hurt by affirmative action. The judge tends to rule in favor of such action by claiming the importance of racial diversity in school and its strict scrutiny. However, racial quota is considered unconstitutional. There are also judges like Clarence Thomas who turns down the cruciality of diversity.
In the last decades, Asian-American has been aggrieved by the affirmative action leading to the law battle between the ivy league school, Harvard University and Asian-American. The data from section II of the paper has shown clearly that Asian-American has been indeed oppressed by the school when it comes to getting the admission to study in Harvard. The qualified SAT score for Asian-American is higher than other races; the acceptance rate for this race is stagnant despite the increase of the application; and not all Asian-American with perfect GPA and plenty extra curriculum activities along with experience are accepted. This reveal that there is quota and racial discrimination in the school. Moreover, as Harvard University is a state university receiving fund from the government, this school indeed infringe equal protection clause of the 14th amendment and Title VI of the Civil Right Acts.
However, thinking about the holistic admission and strict scrutiny, it is difficult to say whether Harvard University discriminate against Asian-American or not. It is clearly subjective because the university consider not only the academic performance but also the potential to growth, characteristic, personalities and the like. As for strict scrutiny, the university turned down the compliant of them being discriminated by using quota to create racial diversity, so strict scrutiny in this case can’t really be applied. However, in case the judge uses strict scrutiny, it would be difficult for Asian-American to win the case because just like Meredith v. Jefferson, the judge would rule upon the importance of the diversity on campus and how it compels to the government interest which is to provide better education to students.
Albeit is affirmative action constitutional as it takes race into consideration and violates the 14th amendment of the constitution as well as the Civil Right Acts? If people are not racist or discriminated against other races, why we need to consider the so-called racial balancing? Does academic achievement alone not enough when it comes to acquiring higher education?
California Institute of Technology, University of California, Berkeley, University of California, Los Angeles and some other universities in California are the university that do not adopt affirmative action. However, there is still diversity on campus. For example, in the University of California, Los Angeles, 23% of the students are Latinos, 5.5% are African-Americans, 28.4% are Whites, and 38.4% Asian-Americans (Khrista and Elissa, 2015). Though the number of African-Americans are low, it is not like there are no other races besides Asian-Americans and White. The reasons behind having a lot of Asian-Americans in those university is also because there are a lot more Asian-Americans in California than African-Americans. Hence, we can conclude that rather than combating racial discrimination and treating everyone the same, affirmative action creates racial prejudice, favor the minorities like Hispanics and African Americans and hurt other races like Asian-Americans and Whites.
Furthermore, affirmative action could also cause harm to African-American students as well. Getting accepted with lower GPA than other races, African-Americans struggle to keep up their work because their academic background is not as strong as other people. As the result, they end up drop out of school. Only the university gets the kudos because they provide diversity for the students. According to Thomas Sowell, with the implementation of the affirmative action, more than 70% of African-American students dropped out from University of California, Berkeley. The reason is because their academic performance mismatched with the university learning environment where there were a lot of brainy people. According to him, the best solution with this would be to accept the students on the basic of their academic capability. He even stated that even if the percentage of the diversity in school is unproportionate, there’re around 300 universities in the United States; therefore, African-American would be able to get the permission from one of those schools that matches with their academic performance (Youtube, 2017).
Moreover, affirmative action also creates tension between students from different races. The students that are not in favor of affirmative action look down on students who are in favor of affirmative action because they think the students who are in favor do not have the same academic capabilities as they do. Interviewed by BBC, Ms. Shum stated that she was one having a hostile conversation with her classmates because her classmate believed she was accepted to study in the university, because of affirmative action not because of academic performance and his achievement. She said that it’s offensive that other students did not acknowledge the strength of the students of color and judged them that they got the admission because of the affirmative action (Clegg and Brenda, 2017).
Last but not least, thinking about long term benefit, affirmative action should not be implemented. Because without affirmative action, students regardless of races will try their best to study so that they could get admitted to the university. Their real capabilities will be shown; their strength and their passion will be there. The future human resource would be incredibly potential. There will be quality over quantity in school. The graduation rate would be high as well as there will be no college drop out because they could not catch up in class.
VII. Conclusion
For me, personally, if I were to make the decision on the case, I would rule in favor of Asian-American students. Looking at the data, it is crystal clear that there is racial quota in the school. Discrimination does occur. The school can’t just use holistic admission to conceal their racial preference. Strict scrutiny can’t be used in the case because it is really subjective. The judge can’t just say it is the compelling interest for the government because diversity helps enhancing student’s learning experience. There should be a stop for this fallacy because affirmative action does nothing besides favor one race and disregard other races. Compelling interest of the government is to provide the best learning experience for the students regardless of races. It is not about making students from races like Asian-American and Whites feel the burden of not getting the chance to go to university because the qualified application for them is set higher than other races. Equal protection clause of the fourteenth amendment of the constitution has now been violated. Title VI of the Civil Rights Acts which was created to ban racial discrimination in educational field has also been destroyed. Reverse racial discrimination has been occurring in the society.
If the purpose of affirmative action is to integrate racial balance between races in educational sector, racial preference, racial quota, and holistic admission should not be used. From my point of view, there should be an equal opportunity for students. Fair competition need to be there, and students need to see and feel the tension of it. If there is a fair competition, students regardless of races would be courageous to study because they know their hard work would pay off. On top of that, students who has been slacking off because they know they have been favored by their race would also try hard and genuinely feel proud of themselves because they know they achieve it in a fairly manner.
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Leaksmy Heng 