The Regents of the University of California present the following argument with regard to their medical school admissions policy at the Davis campus: The central issue presented by this case is whether the Equal Protection Clause of the U.S. Constitution forbids a state professional school to take account of race in admissions to remedy the effects of discrimination against racial minorities. It is unfair and misleading to state that the medical school program admits "less qualified" in place of "better qualified" applicants. It is unfair and misleading to label the medical school program a "quota." The choice of a particular numerical target to define the scope of the program has no constitutional significance. The respondent, Allan Bakke, was not denied admission solely because of his race. Further, the Equal Protection Clause does not bar a state from voluntarily adopting and implementing a policy of increasing the number of medical students and doctors who are fully qualified for admission and who come from minority groups with a history of discrimination against them. The Clause permits race conscious action which is closely tailored to achieving a major public objective. The educational and social purposes to which the policy is tailored justify increasing the number of qualified minority group applicants. Voluntary minority admissions programs raise different constitutional issues from mandatory affirmative action employment programs. Finally, the case should not be remanded for the findings suggested by the United States. (Author/GC)