Texas v. Lesage

Supreme Court of the United States
145 L. Ed. 2d 347, 1999 U.S. LEXIS 8014, 528 US 18 (1999)

ELI5:

Rule of Law:

A plaintiff seeking damages for a discrete governmental decision made under a race-conscious policy cannot establish a cognizable injury if the government proves it would have made the same adverse decision for legitimate, race-neutral reasons.

Facts:

Francois Daniel Lesage, an African immigrant of Caucasian descent, applied for admission to the Ph.D. program in counseling psychology at the University of Texas for the 1996–1997 academic year.
The program was highly competitive, with 223 applications for approximately 20 available spots.
The university's admissions process considered the race of applicants at some stage of its review.
Lesage's application was rejected, while the university offered admission to at least one minority candidate.
The university presented evidence that Lesage was not a competitive applicant, noting that 80 applicants had higher GPAs, 152 had higher GRE scores, and 73 had both higher GPAs and GRE scores.
An admissions committee professor stated Lesage's personal statement was superficial and his letters of recommendation were weak.
The professor affirmed that Lesage's application was rejected early in the review process when the applicant pool was winnowed down to 40 candidates.

Procedural Posture:

Francois Daniel Lesage sued the University of Texas in the U.S. District Court, alleging violations of the Equal Protection Clause and federal civil rights statutes.
The University moved for summary judgment, which the District Court (trial court) granted, finding that Lesage would have been rejected even under a race-neutral policy.
Lesage, as appellant, appealed to the U.S. Court of Appeals for the Fifth Circuit.
The Fifth Circuit (intermediate appellate court) reversed the summary judgment, holding that the 'same-decision' defense was irrelevant because Lesage suffered an injury by being denied the ability to compete on an equal footing.
The University of Texas, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari.

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Issue:

Does a plaintiff who was rejected by a state university under a race-conscious admissions policy have a valid claim for damages under 42 U.S.C. § 1983 if the university can prove it would have rejected the plaintiff's application even under a completely race-neutral process?

Opinions:

Majority - Per Curiam

No. Where a plaintiff challenges a discrete governmental decision as being based on an impermissible criterion, the government can defeat liability for damages by demonstrating it would have made the same decision absent the forbidden consideration. The Court applied the framework from Mt. Healthy City Bd. of Ed. v. Doyle, which holds that even if an impermissible motive was a factor in a decision, a defendant can avoid liability by proving the same outcome would have occurred for legitimate reasons. This principle, typically applied in First Amendment retaliation cases, is equally applicable to Equal Protection claims involving racial discrimination. The Court distinguished this from claims for forward-looking injunctive relief against an ongoing discriminatory policy, where the injury is the inability to compete on an equal footing, which does not require a plaintiff to prove they would have received the benefit.

Analysis:

This decision solidifies the 'same-decision' affirmative defense from Mt. Healthy and explicitly extends its application to Equal Protection claims for damages involving racial discrimination. It establishes a critical distinction between retrospective claims for damages and prospective claims for injunctive relief. For damages claims, the plaintiff must prove causation—that the discrimination was the 'but-for' cause of the injury. This ruling makes it significantly more difficult for individual plaintiffs to succeed in reverse-discrimination lawsuits for monetary damages if they were not otherwise qualified for the benefit sought.

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