Gratz v. Bollinger (2003)
Concurring: O'Connor, Thomas, Breyer
Dissenting: Stevens, Souter, Ginsburg
-Michigan undergrad case
-Literally gave "points" for race
-Dissents are on the "Left"
Rehnquist: Diverse student body is a legitimate reason, but it is not narrowly tailored.
Dissenters: Points are closer to "critical mass"
Ginsburg: it's the exact same as Grutter, the undergrad system is just more frank about it
"The 'percentage plans' are just as race conscious as the point scheme (and fairly so), but they get their racially diverse results without saying directly what they are doing or why they are doing it. Equal protection cannot become an exercise in which the winners are the ones who hide the ball."