In the 1978 case, Regents of the University of California v. Bakke, the U.S. Supreme Court ruled that using racial quotas in college admission decisions violated the Equal Protection Clause. While this landmark decision eliminated racial quotas it did allow race to be considered as one of many admission factors to achieve a diverse student body.

Affirmative action had to be extended to apply to more groups who faced hurdles that others did not systemically encounter. Many university systems have set positive examples by taking proactive measures to diversify their campuses.