The Volokh Conspiracy

Peter Kirsanow on the ABA's "Diversity" Standard for Law Schools:

National Review Online:

The ABA maintains that the latest revision doesn’t require law schools to use race or ethnicity in admissions nor does it require that law schools violate federal or state laws prohibiting the consideration of race or ethnicity. A superficial reading supports such contention. After all, interpretation 211-2 states that law schools may use race and ethnicity in admissions, not that they shall. And revised 211-1 seems to direct schools in jurisdictions that prohibit racial discrimination in admissions to use methods other than preferences to achieve diversity.

Testifying before the U.S. Commission on Civil Rights last month, however, Professor David Bernstein of George Mason University Law School dissected the revisions to reveal that the standards remain, at best, inconsistent with the requirements for lawful racial preferences established by the Supreme Court in Grutter v. Bollinger:

Standard 211 requires law schools to take concrete action to demonstrate a commitment to having a diverse student body. Interpretation 211-2 dictates this be done through a school’s admissions policies and practices. Interpretation 211-3 states that the ABA will measure whether a law school has satisfied its diversity obligation by the totality of the law school’s actions and “the results achieved.”

There are at least two problems with the Standard.

First, it violates Grutter by taking away from the law school the discretion to determine whether diversity is essential to its mission. Under Grutter, the Supreme Court will defer to a law school’s judgment in this regard; i.e., the Court gives the school a presumption of good faith in defining its mission.

Standard 211, however, completely overrides the school’s discretion in determining whether diversity is essential to its mission. Instead, the ABA mechanically imposes diversity (more accurately, the ABA’s narrow definition of diversity) upon every school’s mission, regardless of an individual finding of pedagogical need. This destroys the presumption of good faith critical to the legality of a school’s racial preference program. Without the element of good faith, such programs devolve into raw racial balancing and don’t survive strict scrutiny.

Second, the Standard provides no safe harbor. Since the Standard measures a school’s compliance by results achieved, the only way a school can satisfy 211 practically is by using massive preferences.

Mike BUSL07 (mail) (www):
My biggest problem with the ABA standards is that they reveal either utter incompetence or bad faith on the part of the drafters.

As practically everyone who pays attention to these issues now knows, ham-fisted efforts to recruit minorities inevitably bring about student bodies where blacks and hispanics are the least qualified based on their LSAT's and GPA's.

Admitting a kid with an 150 LSAT into, say, Cornell Law is a good way of ensuring that he will finish at the bottom of the class, whether he is black, white, or whatever else.

Forcing law schools to admit underqualifed candidates is self-laudatory leftism with disregard for consequences, such as they are for the law schools, and perhaps more importantly for the intended beneficiaries.
7.13.2006 11:25am
Ian Samuel (mail) (www):
The NRO analysis is very flimsy. Grutter is silent on the question of what must motivate the schools' determinations that diversity is important. Presumably there are many cross-cutting reasons. I'm unsure where "good faith" fits into equal protection analysis. Deference to diversity as a rationale is not the same thing as deference to a rationale just because it is in "good faith." Presumably, the law schools could not implement "good faith" quotas, nor would it matter if a news article were released showing that adcoms were cynically advancing diversity interests to look cool.

Moreover, the second objection appears to read out "the totality of the law school's actions" to focus, laserlike, on "the results achieved."

Complaining about the ABA standard is one thing, but to stretch those complaints to implicate Grutter borders on bad faith.
7.13.2006 11:38am
DavidBernstein (mail):
Ian, it's not specified in the NRO piece, but the ABA "interpretation" to the Standard explicitly states “This Standard does not specify the forms of concrete actions a law school must take to satisfy its equal opportunity and diversity obligations. The determination of a law school’s satisfaction of such obligations is based on the totality of the law school’s actions and the results achieved.” As for Grutter, the explicit basis for O'Connor's opinion was deference to Michigan's judgment that diversity was crucial to its academic mission.
7.13.2006 11:51am
Neal R. (mail):
Does Grutter really stand for the proposition that it is impermissible to "tak[e] away from the law school the discretion to determine whether diversity is essential to its mission"? It's been a while since I read the opinion, but I thought the holding was that race is a compelling governmental interest. That's not the same as saying that schools must be granted discretion to consider or not consider it. How does it "violate Grutter" for the ABA to force law schools to do what Grutter permits them to do?
7.13.2006 12:35pm
Ian Samuel (mail) (www):
David: I appreciate the clarification. Still: "the totality of the law school's actions" are also considered, in concert with the results achieved. That doesn't require the use of quotas. In fact, Boalt Hall has demonstrated how to achieve diversity without even consciously using racial preferences--presumably, they will not be in hot water with the ABA, yes?
7.13.2006 2:34pm
Toby:
These things always have an internal un-analyzed self re-buttal. If I have 20 law graduates who went to the same prep school / ivy league / law school, do Ihave a diversity of opinions and life experiences that will enhace whatever it is diversity enhances? Is the most important fact about any crowd, even as undiverse as the above, the precise mix of skin hues and genitals involved? And if this is so important, then that would seem justify using race/color/gender as a selection criterion to achieve desired results, of which diversity so defined may not be the most important.

If diversity of thought, or styles of argument (which is presumeably what I want whenI hire a lawyer) were important, wouldn't it be better to mix in one guy who grew up somewhere else, went to different schools, had a different life experience. And that requiremnt could be better filled with completely blind (to diversity factors) resumes.

Every time someone launches into a defense of diversity, I feel I am in the final scenes of the movie "Bananas". THe revolutionaries know there leader has gone crazy and must be deposed when he declares: (from memory decades old, so give me a break)

"The heal and welfare of my people is paramount. From now on, all people must change their underwear every day. Furthermore, all underwear willl now be worn on the outside, so we can check."
7.13.2006 3:56pm
Negative Reaction:
The knee-jerk ABA has made it clear that all must bend their knees on the altar of affirmative action---the law be damned!

Diversity Uber Alles!
7.13.2006 5:30pm
Bruce Hayden (mail) (www):
I think that the good faith comes in is that if a school decides that diversity is important, then the courts will defer it it. But here, we don't have a state school independantly making the decision, but, rather, an unelected, unrepresentative, bunch of attorneys making the decision for most of the law schools in the entire country.
7.13.2006 5:43pm