This legal document asserts that the judgment of the Court of Appeals upholding the constitutionality of the University of Michigan Law School's race-conscious admissions policy should be affirmed. It argues that research evidence in the record supports the compelling interest in promoting educational diversity (the Gurin Report supports the compelling interest in promoting educational diversity, and the "strong basis in evidence" requirement is not mandated for non-remedial university admissions). It also argues that research studies support the Law School's compelling interest in promoting educational diversity (student body diversity improves education outcomes in legal education, and student body diversity and diverse learning environments challenge racial stereotyping in education). Finally, it asserts that the Law School's admissions policy is narrowly tailored to promote educational diversity (the Law School's admissions policy employs race modestly and flexibly, "critical mass" is a flexible concept designed to prevent tokenism and stereotyping, race-neutral policies are less efficacious than race-conscious policies in promoting educational diversity, and a "percent plan" is not a viable alternative to the Law School's race-conscious policy. (SM)