Allan Bakke was a white man twice rejected by the medical school at the University of California, Davis. The school reserved 16 of 100 seats for minority applicants. Bakke sued, arguing this quota violated the Civil Rights Act of 1964 and the Fourteenth Amendment. On June 28, 1978, the Supreme Court delivered a split decision that satisfied no one completely and shaped American life for a generation.
Justice Lewis Powell wrote the controlling opinion in a fractured 5-4 ruling. The Court found the specific quota system at UC Davis unconstitutional and ordered Bakke admitted. It stated that rigid racial classifications violated the Equal Protection Clause. In the same breath, Powell argued that achieving a diverse student body was a compelling state interest. Race could be used as a "plus" factor in a holistic review of an applicant's file. The decision explicitly rejected both pure colorblindness and reparative justice as constitutional rationales, anchoring the defense of affirmative action instead to the educational benefits of diversity for all students.
The ruling created a durable but unstable compromise. It gave legal permission to consider race while stripping away the most straightforward tool to increase minority representation. Universities developed complex admissions systems to navigate this narrow path. The decision framed diversity as a commodity benefiting the institution, a rhetorical pivot that would dominate future debates. For twenty-five years, the Bakke framework held, challenged but never overturned, until the Court revisited its own logic in the 2003 Grutter v. Bollinger case, which upheld Powell's diversity rationale before ultimately rejecting it in 2023.