In writing for the majority in the U.S. Supreme Court�s landmark 2003 ruling in Grutter v. Bollinger, Justice Sandra Day O�Connor found the University of Michigan Law School�s use of affirmative action as part of its admissions process to be constitutional, so long as it is narrowly tailored and not reliant on a quota system (as was the downfall for Grutter�s companion case, Gratz v. Bollinger, in which the court struck down Michigan�s undergraduate bonus point system for minority applicants).
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