4 Chapter Two
2. The plurality Bakke case found a hard quota to be unconstitutional. In 2003, the Supreme Court
decided a college admissions affirmative action case, Grutter v. Bolinger (T539 U.S. 306, 123 S.Ct.
2325 (2003)) and allowed a college admissions program that focused on diversity with race and
ethnic background being only one of many factors considered. A race specific scholarship program,
however, is more akin to a hard quota such as in Bakke and is thus probably unconstitutional. One
has to use the word probably since Bakke was a plurality and the Grutter case did not provide any
clear renunciation or endorsement of the Bakke prohibition of a hard quota.
3. E-mail is a “push” phenomenon in which consumers do not ask for the “spam” they receive. Thus,
government regulation can be characterized as consumer protection. Web sex, however, is a “pull”
phenomenon in which customers seek out, and often pay for, the information they obtain. Thus,
consumers appear to need less regulation of web sex than of unwanted e-mail. For example, the
4. In 2003, in Lawrence v. Texas, discussed on pages 87-88, the Supreme Court held in a divided
opinion that private homosexual sexual relations are protected as a liberty right. Thus a law
prohibiting sodomy is considered unconstitutional. The Lawrence decision reflected a major change
5. The court initially avoided the issue by stating that the School District’s use of the racial tiebreaker
violated Washington state law. Because “we look first to state law to resolve this issue, in
accordance with our longstanding principle that courts should avoid making federal constitutional
decisions unless and until necessary.” On rehearing en banc, the Court of Appeals, Fisher, Circuit
Judge, held that:
(1) school district had compelling interest in securing educational and social benefits of racial and