Why Latina/as Need More than Twenty–Five Years of Affirmative Action
Kevin R. Johnson
In a pair of much,watched cases, the US Supreme Court in 2003 allowed affirmative action to survive, while not quite declaring it alive and well. The decisions in Gratz v. Bollinger and Grutter v. Bollinger put to rest, at least for a short time, a controversy that raged in the 1990s. In 1978 the Court placed its reluctant, somewhat obtuse imprimatur on affirmative action in the famous case of Regents of the University of California v. Bakke (1978) . Since then, race, conscious affirmative action programs have risen and, at least in some jurisdictions, fallen ( most notably in the 1996 Hopwood v. Texas ruling) . In the latest duo of cases, both filed against the University of Michigan, the Court announced a truce of sorts in the affirmative action hostilities. In so doing, however, the Court has virtually guaranteed that the debate over affirmative action will likely return in the not,too,distant future .
The Court’s decisions in the two University of Michigan cases-one invalidating its race,conscious undergraduate admission program, the other upholding the law school’s race,conscious admissions-raise fascinating questions. This essay considers one issue, that of a set time limit on affirma, tive action. In Grutter, Justice Sandra Day O’Connor, writing for a majority of the Court, bluntly stated the Court’s expectation that affirmative action programs like the one employed by the elite University of Michigan Law School should no longer be necessary in twenty,five years. The Court’s stated sunset of affirmative action in all likelihood will encourage additional legal challenges to such programs 1·n 2028 ·f , 1 not sooner.
356 From the Fall 2004 issue of Aztlan: A Journal of Chicano Studir.1 ( vol. 29, nL>, 2 ).

Why Latina/os Need More than Twenty-Five Years of Affirmative Action
The twenty-five-year time limit announced by Justice O’Connor grabbed immediate public attention. At first blush, the announcement seemed overly optimistic, if not woefully out of place in a judicial opinion. However, several major Supreme Court decisions have embraced the idea that affirmative action programs to remedy past discrimination are “temporary” measures and should be eliminated when no longer necessary (Adarand Constructors , Inc . v. Pena 237 (1995]; City of Richmond v. ] . A . Croson Co . 510 (1989]) . Indeed, the Court has expressly required that affirmative action programs to remedy past discrimination have time limits.
A time limit ensures periodic review of a race-based program to make sure that it is maintained only if needed or, if necessary, modified to better achieve its goals. There is a need for constant evaluation and reevaluation of the effectiveness of efforts to reach out to all segments of a state’s popula-tion, even in those states that lack the ability to engage in race-conscious affirmative action. By requiring periodic review, the twenty-five-year limit may bring much-needed pressure to bear on universities to fine-tune affirma-tive action programs and regularly evaluate their outcomes.
Nonetheless, the Court’s announcement of the twenty-five-year limit, which came out of the blue in Grutter, is subject to criticism. An obvi-ous objection is that two and a half decades will not be long enough to eliminate the need for affirmative action at elite public universities, which today lack many minority students despite having had affirmative action programs in place for decades. Racism has existed for centuries in the United States. Although the most blatant forms of racial discrimination have been declared unlawful, their legacy has proven difficult to remedy, as shown by persistent housing, employment, and school segregation as well as substantial income and wealth disparities between racial groups. Nor does the nation appear on the road to educational equity. Public elementary and secondary schools remain racially segregated to a large extent, in practice if not in law. Put bluntly, the serious deficiencies in many of the schools serving African American and Latina/a children seem nearly impossible to remedy in time to benefit this generation of public school students.
But there is a more fundamental intellectual flaw in the Supreme Court’s projected end of the need for affirmative action. The Court accepted the affirmative action plan of the University of Michigan Law School as serving the compelling state interest of ensuring a diverse student body. Race-conscious programs designed to achieve a “critical mass” of minor-ity students would not seem to demand any expiration date, because an academic institution could always desire to pursue a racially diverse student

Kevin R. Johnson
body; such a student body may not naturally result a~sen_t consideration of race. Affirmative action intended mainly t~ be_ re~ed,1al, m c~ntr~st, would not be necessary after the impacts of an mstttut10n s past discrimination had been remedied. Put differently, universities could still want to strive for a racially diverse student body even if an institution’s discriminatory history had been fully addressed (or, indeed, if the institution had never discriminated on the basis of race) .
Moreover, even if one is sympathetic to the notion of time limits, an institutional objection to the Court’s twenty-five-year pronouncement exists. The Court arguably should not be in the business of establishing firm limits on the duration of an affirmative action program. Political decision makers, not the courts, ordinarily establish time limits on claims for relief, known as statutes of limitations, and sunset provisions for laws, both of which by nature are somewhat arbitrary. Such periods reflect a wide variety of policy judgments best (and ordinarily) made by legislatures and policy makers.
Consequently, the University of Michigan Law School, not the US Supreme Court, arguably should have included a time for periodic review of its affirmative action program-whether remedial or diversity-driven-and its possible improvement or elimination. Without a time limit to ensure regular review of the program, the argument goes, the Michigan law school’s affirmative action program was not “narrowly tailored” to further a compelling state interest, the test applicable to the use of racial classifications by the state.
Along these lines, the argument could be made that the Supreme Court lacked the institutional competence to arbitrarily set the time limit, a deci-sion that is the legitimate province of the political branches of government. Justice O ‘Connor in Grutter offered little justification or reasoning for the twenty-five-year period, but simply declared it to be. Some might speculate that th is statement, which (as lawyers are wont to say) is technically dicta, was included in the opinion as part of a political compromise to build a majority on the Court that would leave intact the University of Michigan Law School’s affirmative action program. That tends to undermine the legitimacy of the Court’s pronouncement that twenty-five years should mark the end of affirmative action.
This paper analyzes the Supreme Court’s statement in Grutter about the future of affirmative action. It first places into context the twenty-five-year limit announced by Justice O ‘Connor. It then reviews whether Latina/os, the largest minority group in the United States and one projected

Why Latina/as Need More than Twenty-Five Years of Affirmative Action
to grow significantly in the next twenty-five years, can be expected to be significantly represented in university student bodies with the Court’s projected end of affirmative action in 2028.
The University of Michigan Cases
The Gratz and Grutter decisions marked the end of a series of legislative and judicial limits on affirmative action that began in the 1990s. In making these decisions, the Court has sent a powerful signal to the nation that race-conscious affirmative action is not per se unlawful and that carefully crafted programs can survive constitutional scrutiny. The cases promise to reinvigorate affirmative action at universities across the United States, at least for a time. As summarized by one prominent Supreme Court watcher, the decisions “adhered to the position articulated by Justice Lewis Powell in Bakke a quarter century ago: Diversity is a compelling state interest in education and universities may use race as a factor to ensure diversity, but quotas or numerical quantification of benefits is impermissible” (Chemer-insky 2003, 369) .
In Grutter, the Court upheld the University of Michigan Law School’s program that ensured individual review of each applicant’s file and allowed race to be considered as one of many factors in the admission decision. This was seen as supporting the law school’s pursuit of a diverse student body with a “critical mass” of minority students (Grutter, 2338-45). The Court emphasized that deference must be afforded to the university in its exercise of academic judgment (2339). In contrast, the Court in Gratz invalidated the undergraduate admission scheme at the University of Michigan, which relied on a point system in which minority applicants received twenty points for simply being a minority. The Court found that this program was not narrowly tailored to further the desired end-a racially diverse student body (2430-31). According to the Court, the point allocation based on race almost conclusively determined whether or not an applicant would be admitted and did not in fact constitute individual review of each application (2428-30) .
Grutter and Gratz together make clear that the use of race in an affir-mative action program must be narrowly tailored to satisfy the compelling state interest of securing a diverse student body. The Court believed that the individual review of each applicant’s file on its merits as done by the law school was the quintessence of narrow tailoring (Grutter, 2343 ). In contrast, the point system employed in the undergraduate admission scheme made

Kevin R. Johnson
individual review impossible and therefore the program was not narrowly tailored to advance a compelling state interest (Gratz, 2428-30) .
The results of the University of Michigan Law School’s affirmative action program leave serious doubt about how effective it was in ensuring a diverse student body. In fall 2002, the school had an entering class with a total minority population of about 25 percent of the class, but with no Mexican Americans among its 6.8 percent Hispanics and only 6 percent African Americans. By comparison, the University of California at Berkeley School of Law, with no affirmative action in place due to the passage of a ballot measure (Proposition 209) in 1996, had almost 40 percent minority students in its first-year class, with African Americans making up more than 5 percent and Hispanics almost 12.5 percent, including 7 percent of Mexican ancestry (ABA-LSAC 2003, 150, 426) . Although demographic differences exist between Michigan and California, both law schools are elite institutions that pride themselves on drawing their student bodies from across the country.
The Court’s decision in Grutter, which upheld the Michigan law school’s affirmative action program, may help small numbers of minorities continue to gain admission. Equally important, the cases had emerged as the focal point of a national campaign to maintain affirmative action and to fight the perceived resegregation of the public universities. The Court’s decision undoubtedly will allow for the possibility of affirmative action programs at many schools. Moreover, the message of encouragement to people of color was much needed after years of legal and political attacks on affirmative action.
The most curious part of the decision in Grutter, which was written by Justice O’Connor, came rather abruptly near the end of the opinion. In upholding the University of Michigan Law School’s affirmative action program, the Court emphasized that
race-conscious admissions policies must be limited in time. This require-ment reflects that racial classifications, however compelling their goals, are potentially so dangerous that they may be employed no more broadly than the interest demands. Enshrining a permanent justification for racial preferences would offend this fundamental equal protection principle. (Grutter , 2346; emphasis added)
The Court added that “the durational requirement can be met by sunset provisions in race-conscious admissions policies and periodic reviews to determine whether racial preferences are still necessary to achieve student body diversity” (2346) .

Why Latina/as Need More than Twenty,Five Years of Affirmative Action
But the Court did not conclude with the general admonition that there b an end in sight to race,conscious affirmative action and that such must e
progra ms are “temporary.” Rather, the Court continued:
It has been 25 years since Justice Powell first approved the use of race to further an interest in student body diversity in the context of public higher education. Since that time, the number of minority applicants with high grades and test scores has indeed increased . . .. We expect that 25 years from now, the use of racial pref er enc es will no longer be necessary to further the interest approved today . (2346-47; emphasis added)
The stated expectation that affirmative action would no longer be necessary in twenty, five years provoked comment and disagreement among the justices. In a concurring opinion, Justice Ruth Bader Ginsburg challenged the limitation: “it was only 25 years before Bakke that this Court declared public school segregation unconstitutional, a declaration that, after prolonged resistance, yielded an end to a law,enforced racial caste system, itself the legacy of centuries of slavery” (2347) . Citing the continuing deficiencies in the public education of many minorities in the United States, she cautioned that “from today’s vantage point, one may hope, but not firmly forecast , that over the next generation’s span, progress toward nondiscrimination and genuinely equal opportunity will make it safe to sunset affirmative action” (2348; emphasis added). In sum, Justice Ginsburg was considerably less sanguine than Justice O’Connor that the need for affirmative action would evaporate within twenty,five years.
ChiefJustice William Rehnquist disagreed with the majority and con, tended in a dissenting opinion that “the Law School’s program fails strict scrutiny because it is devoid of any reasonably precise time limit on the Law School’s use of race in admissions” (2365, 2369; emphasis added) . Justice Rehnquist contended that the lack of a stated time limit in the law school affirmative action program rendered it constitutionally infirm (2370) . In a separate dissent, Justice Anthony Kennedy in a less opinionated fashion commented that he found it “difficult to assess the Court’s pronouncement that . •11 b ry 25 years from race,consc1ous admissions programs w1 e unnecessa now” (2373 ).
C . J · Clarence Thomas oncurring in part and dissenting m part, UStlCe ” Id h read h ·vely to ho t at t e majority’s twenty,five ,year language expansi .
11 1 . 25
r . l . . ·n be I ega m acia discrimination in higher education admissions wi cl ” ” h . ity does not an Years (2350; emphasis added) . He argued that t e maJor . dentials
ca . ‘d hat the gap m ere Ilnot rest lts time limitation on any evi ence t

Kevin R. Johnson
between black and white students is shrinking or will be gone in that time frame” (2364; emphasis added) . At the same time, J~stice Thomas does
l · · ffict’ent to increase African Amencan representation not see t 1ts tune as su at the top law schools without affirmative action. If one r~ads be~we~n the lines, Justice Thomas’s opinion reflects skepticism about, tf ~ot dtsdam ~or, efforts by university administrators to implement race,consctous affirmattve action while also seeking to maintain their schools’ elite status.
Latina/as and Affirmative Action After Grutter and Gratz The Supreme Court decisions in Grutter and Gratz will have important impacts on higher education in the United States as universities seek to enroll diverse student bodies. The Court’s projected end of the need for affirmative action in twenty,five years, however, seems misplaced in several respects.
To this point in US history, racism and racialization unfortunately have been a constant. The end of the need for affirmative action, whether based on a diversity or remedial rationale , rests to a certain extent on the end of racial inequality.
Latina/as, along with African Americans, Asian Americans, Native Americans, and other groups, have experienced racial discrimination in the United States for centuries. The intensity and manner of discrimina, tion toward each group have fluctuated over time, depending on national and local circumstances; for example, discrimination against Arabs and Muslims flared after September 11, 2001 . But so long as we see racism and racial inequality continuing in the United States, the need for affirmative action presumably will continue as well.
True, periodic review of affirmative action programs as approved by Grutter may help improve them and their ability to attain the stated goal of racial diversity in higher education. Racism and its manifestations change with the times; the remedies must change as well. The problem is that the Supreme Court’s linear view of racism as a pr bl f h h ·11 . . . . – o em o t e past t at wt dtmtmsh m future-fails to account for th · , d · d . . e ractsm s ynamte nature an tts ~osstble p~rmanence in US society (Bell 1992; Omi and Winant 1994) . Thts dynamtsm and permanence militat . f f . . . f
. . e m avor o penod1c revtew o affirmattve actton programs as well as th . . eir mamtenance.
Importantly, an effective review of affi. . . . 1 k rmattve action programs reqmres a separate oo at the enrollment of d ‘ff;
including Latina/as a d h . i erent underrepresented groups, n t etr treatment . US . h
m society. Latina/as, wit

Why Latina/as Need More than Twenty-Five Years of Affirmative Action
their different experiences, may have different rationales than African Americans for affirmative action. This simple truth is often ignored in the debate over affirmative action.
Discussion of the need for affirmative action often centers on African Americans and whites, thus falling into the trap of seeing civil rights only in terms of the black-white paradigm. Race relations in the United States are considerably more complex, however, with many more than just two races. Although slavery of African Americans ended well over a century ago, its horrible legacy is often the first justification offered for affirmative action. Subordination of Latina/as did not occur through the formal institution of slavery. Nevertheless, Latina/as have suffered forced labor and peonage, segregation, discrimination, hate violence, and more in the United States. The wrongful deportation of approximately one million persons of Mexican ancestry in the 1930s, mass deportations under Operation Wetback in 1954, housing and school segregation, and aggressive immigration enforcement directed at Latina/as are but a few examples of the discrimination against Latina/as in the twentieth century (Acuna 2003 ; Almaguer 1994 ). This history of discrimination against Latina/as, which many observers contend continues to this day, may serve as a rationale for affirmative action.
The Supreme Court’s endorsement of a twenty-five-year time limit on affirmative action in Grutter is especially flawed with respect to Latina/as, who as a group are socioeconomically disadvantaged compared to Anglos and who continue to experience hostile attitudes directed at Latina/a immigrants ( even though the majority of Latina/as in this country are native-born US citizens). Already the largest minority group in the United States, Latina/as are projected to grow substantially in numbers over the next fifty years (Johnson 2002, 1492-96, 1499-1500) . The impact that this growth will have on the need for affirmative action is far from clear. If history is any indicator, however, discrimination and segregation targeted against Latina/as will continue, with negative impacts on the representation of Latina/os in higher education. In this vein, the Mexican American Legal Defense and Educational Fund (2003) submitted an amici curiae brief in the Michigan cases contending that the history of discrimination against Latina/as-and its continuation-supports affirmative action in higher education for Latina/as.
Consider the status of Latina/as in elementary and secondary educa-tion in the Golden State. In California Latina/as make up over 40 percent of students in public elementary and secondary schools but contribute far smaller percentages of state college and university student bodies (Johnson

Kevin R. Johnson
and Martfnez 2000, 1239-46). Like African Americans, Latina/os are disproportionately represented among s~ud~nts in poore~ school districts. The lack of equal educational opportunity m the formative years makes it difficult for many Latina/o students to compete for scarce higher educational opportunities. Yet, as the Latina/o population has increased in California, the funding per pupil has dropped precipitously ( 1239-4 3).
Latina/os are likely to face continuing problems gaining access to a quality education. School finance issues, which have proven extremely difficult to remedy (Johnson and Martfnez 2000, 1235-37; Ryan 1999), create educational disparities that make it difficult for Latina/os to compete for admission to selective universities. Combined with the lack of affirma-tive action in California, which has stalled any effort to increase Latina/o representation in the public universities, the continuing poor quality of many public schools serving Latina/as may well doom any hopes that this population will increase their representation in higher education by 2028.
Some of the educational inequities facing Latina/os have worsened, not improved, in the last decade. For much of the 1990s, no affirmative action existed in states with some of the highest Latina/o populations, namely California, Texas, and Florida. Nor will there be any change in California after Grutter and Gratz, as the state’s voters in 1996 passed Proposition 209, an initiative that bans race-conscious programs of any type, including those designed to remedy general societal discrimination and to secure a racially diverse student body. Thus, the state with the largest Latina/o population will lack affirmative action during a period when it will be available in other states. This likely will have negative consequences for the socioeconomic status of Latina/os in California for generations.
Even when affirmative action existed in California, Latina/as, as well as African Americans, were seriously underrepresented in the University of California system (Kidder 2003, 32, 34, tables 4-7). This underrepre-sentation is not limited to public universities in California but is a problem in Florida, Texas, and many other states. Recall that only a handful of ~tina/o~~d no persons of Mexican ancestry-enrolled at the Univer-sity of M1ch1gan Law School in the fall of 2002, on the eve of the Court’s momentous affirmative action decisions.
For Latina/as acces t h· h d . . . -. . ‘ s O tg er e ucat1on also implicates 1mmigra tlon and immigrant Th S d . . s. e upreme Court has held that undocumente 1mm1grant child e . bl ‘ I
r n cannot constitutionally be barred from the pu ic e ementary and s d h econ ary sc ools (Plyler v. Doe [19821). However, undocumented stude t h •
n s, even t ose brought to the United States by their

Why Latina/as Need More than Twenty-Five Years of Affirmative Action
parents at a young age, are effectively denied access to public universities in many states because they are charged prohibitively high nonresident fees, even if they are long-time residents of the state. Controversy has swirled around undocumented immigrant access to public universities (Olivas 1995; Romero 2002) , and a political movement to allow undocumented immigrants to pay in-state resident fees at public colleges and universities has garnered congressional attention.
Because Latina/os experience continuing inequality in education, the hope for a level playing field among college applicants in twenty-five years is little more than a pipedream. The persistence of political, social, and economic disparities between Latina/os and Anglos make it apparent that twenty-five years is much too short a period to expect the need for affirmative action for Latina/as to end. Consequently, if the nation remains truly committed to racial equality in 2028, affirmative action, or aggres-sive programs directed at improving the public elementary and secondary educational systems, almost certainly will be necessary.
In his opinions in the University of Michigan cases, Justice Thomas raises issues about affirmative action that might concern Latina/os, as well as other minorities. He emphasized in both Grutter and Gratz that the cases before the Court did not involve a claim that the University of Michigan had discriminated among similarly situated Latina/os and African Americans (Grutter, 2350, 2363; Gratz, 2433) . This suggests that he would have viewed the case differently if the claim had been that certain racial minorities were being discriminated against in favor of other minorities to ensure a “critical mass” of each minority group in the student body. Besides raising the specter of pitting minority groups against each other, Justice Thomas has suggested a strategy to be employed by future opponents of affirmative action, perhaps using minority plaintiffs to claim discrimination against them in favor of other applicants of another minority group.
Over time, black-brown friction has arisen occasionally in the affirma-tive action debates. Some advocating the rights of African Americans have claimed that Latina/os should not be eligible for affirmative action and that they are taking seats from African Americans (Johnson 2002, 1501 and n.107). Latina/os and African Americans have their own distinct histories in the United States, with both similarities and differences. Some observers claim that immigrants as a general rule should not be eligible for affirmative action, a deeply contentious position to many Latina/os. Although the groups’ interests often converge, tensions between Latina/as and African Americans no doubt exist on affirmative action and other issues. Both groups musr

Kevin R. Johnson
. constructive dialogue about affirmative action and attempt to engage m a . . k h . unities· it would be a serious m1sta e to presume a its impact on t e1r comm ‘ . . . n
· h oups on this potentially volatile issue (Vaca 2004) alliance between t e gr ·
TI U . •t f Mi’chigan affirmative action cases no doubt will be of ,e nivers1 y o monumental importance to public universities that have, or are contem-plating, affirmative action programs. The curious twenty-five -year sunset provision announced by the Supreme Court raises many questions, ranging from the unlikelihood that the last vestiges of centuries of discrimination and segregation will disappear in the next twenty-five years to the competence of the Court to establish a time limit. Because there is no quick fix to the legacy of racial discrimination in the United States, the proposed elimination of affirmative action in one generation appears to be wishful thinking.
However, the Court correctly understood the need for regular moni-toring of affirmative action programs. New ideas and programs must be explored and tested whenever possible as the nation seeks to address the serious underrepresentation of racial minorities in higher education. Affir-mative action programs must be monitored to prevent them from becoming a crutch used by universities to claim that they are addressing the problem of educational inequity between racial groups.
Specifically, the idea that Latina/os will not need affirmative action to ensure representation in public colleges and universities is misguided. It ignores the ongoing discrimination against Latina/os in US society and the rampant housing, school, and employment segregation facing this group. In particular, the problem of poorly funded minority public elementary and secondary schools almost certainly cannot be remedied in the short term. That alone is enough to virtually guarantee that Latina/os as a group will not be able to compete on that mythical “level playing field” with white students for admission to el· t . . . . 1 e un1vers1t1es m twenty-five years.
Notes Parts of this article are adapted f ” . Action?,” Constitutional C rom The Last Twenty Five Years of Affirmative
ommentary 21 1 ( Ad l de la Torre for organizin bl ‘ . ‘ no. 2004 ). Thanks to Professor ea 200 . g pu 1cat1on of th · · C t’s 3 affirmative actio d . . is senes of papers on the Supreme our n ec1s1ons.

Why Latina/as Need More than Twenty-Five Years of Affirmative Action
Works Cited ABA-LSAC (American Bar Association-Law School Admissions Council) . 2003.
Official Guide to ABA-Approved Law Schools . Newton, PA. Acuna, Rodolfo. 2003. Occupied America: A History of Chicanos . 5th ed. New York:
Longman. Almaguer, Tomas. 1994. Racial Fault Lines: The Historical Origins of White Supremacy
in California . Berkeley and Los Angeles: University of California Press. Bell, Derrick A., Jr. 1992. Faces at the Bottom of the Well: The Permanence of Racism.
New York: Basic Books. Chemerinsky, Erwin. 2003. “October Term 2002: Value Choices by the Justices,
Not Theory, Determine Constitutional Law.” Green Bag 6, no. 2: 367-77. Johnson, Kevin R. 2002. “The End of ‘Civil Rights’ as We Know It? Immigration
and Civil Rights in the New Millennium.” UCLA Law Review 49: 1481-1511 . Johnson, Kevin R. , and George A. Martfnez. 2000. “Discrimination by Proxy: The
Case of Proposition 22 7 and the Ban on Bilingual Education.” UC Davis Law Review 33: 1227-76.
Kidder, William A. 2003. “The Struggle for Access from Sweatt to Grutter: A History of African American, Latino, and American Indian Law School Admissions, 1950-2000.” Harvard BlackLetter Law Journal 19: 1–42.
Mexican American Legal Defense and Educational Fund. 2003 . “Amicus Briefs in Grutter v. Bollinger and Gratz v. Bollinger, in Support of the University of Michigan: Brief of Mexican American Legal Defense and Educational Fund et al. as Amici Curiae.” Berkeley La Raza Law Journal 14: 1-23 .
Olivas, Michael. 1995. “Storytelling Out of School: Undocumented College Resi-dency, Race, and Reaction.” Hastings Constitutional Law Quarterly 22: 1019-86.
Omi, Michael, and Howard Winant. 1994. Racial Formation in the United States . New York: Routledge.
Romero, Victor. 2002. “Postsecondary School Education Benefits for Undocumented Immigrants: Promises and Pitfalls.” North Carolina Journal of International Law and Commercial Regulation 2 7: 3 9 3–418.
Ryan, James E. 1999. “The Influence of Race in School Finance Reform.” Michigan Law Review 98: 432-81.
Vaca, Nicolas C. 2004. The Presumed Alliance: The Unspoken Conflict Between Latinos and Blacks and What It Means for America. New York: Rayo.
Cases Cited Adarand Constructors, Inc. v. Pena, 515 U.S. 200 (1995). City of Richmond v. J. A. Croson Co., 488 U.S. 469 (1989). Gratz v. Bollinger, 123 S. Ct. 2411 (2003 ). Grutter v. Bollinger, 123 S. Ct. 2325 (2003) . Hopwood v. Texas, 78 E3d 932 (5th Cir.), cert . deniedsubnom., 518 U.S. 1033 (1996)-Plyler v. Doe, 457 U.S. 202 (1982) . Regents of the University of California v. Bakke, 438 U.S. 265 (1978)-


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