In striking down racial-admissions preferences at the University of Michigan's liberal-arts college in Gratz v. Bollinger while upholding its law school's race-based policies in Grutter v. Bollinger, the court found campus diversity compelling enough to justify some consideration of race. But the court subjected race-based admissions to new limits in time and scope. Taken together, the twin decisions make it clear that race must be used in a "flexible, nonmechanical way" and cannot generally be a "decisive" factor. Instead, colleges must engage "in a highly individualized, holistic review of each applicant's file, giving serious consideration to all the ways an applicant might contribute to a diverse educational environment." As Gratz stated, the "critical criteria" in such a review "are often individual qualities or experience not dependent upon race but sometimes associated with it." Yet higher-education institutions may n...