In the early 1970s, the medical school of the University of California at Davis devised a dual admissions program to increase the representation of disadvantaged minority students. Allan Bakke was a white male who applied to and was rejected from the regular admissions program. Simultaneously, minority applicants with lower grade point averages and testing scores were admitted under the specialty admissions program. Bakke filed suit, alleging that this admissions system violated the Equal Protection Clause and excluded him based on race. The Supreme Court found for Bakke against the rigid use of racial quota and established that race was a permissible criterion.

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