“It is a near-total victory...not a ‘mixed decision,’ because it tells universities what they can do to have a constitutional affirmative action plan,” Greenhouse, who is also a Crimson editor, wrote in an e-mail. “It validates Bakke and puts it on a broader and more forward-looking basis than before.”

But foes of affirmative action saw a less consistent picture.

“It was definitely a split decision,” said Curt Levey, director of legal and public affairs for the Center for Individual Rights, a non-profit Washington law firm which opposes racial preferences.

The critical distinction raised in Justice Sandra Day O’Connor’s majority opinion in Grutter was the “individualized, holistic review” of each application in the law school’s policy, as opposed to the automatic boost granted by LSA’s points system. The opinion stressed the need for affirmative action policies to be “narrowly tailored.”

The Grutter ruling relied on the contention that diversity in higher education is a “compelling state interest that can justify the use of race in university admissions”—and that this interest trumps concerns about discrimination under the Equal Protection Clause of the Fourteenth Amendment. This view was first articulated by former Justice Lewis F. Powell’s majority opinion in Bakke.

The Court also hewed to Powell’s insistence that race be used only as a “plus,” barring quota systems and stressing “flexibility.”

In the Bakke decision, the Court struck down the University of California Medical School’s strict quota system for minority applicants. But Powell’s decision came from a divided court that came together only on a few central points of the case.

In casting the decisive vote, he wrote an opinion that no other justice joined with in full, although four others concurred in part. The result is that while Bakke had widely been considered the standard, it was unclear whether the ruling was ever good law, a question put to rest on Monday.

In defending the use of race in university admissions decisions, Powell cited Harvard’s policies as a model in Bakke. O’Connor explicitly echoed Powell on this point, referring multiple times to the “Harvard plan” as ideal. She also cited a book co-authored by former University President Derek C. Bok and a study on affirmative action by Gary Orfield, who is the founding co-director of the Civil Rights Project at Harvard, and Harvard research assistant Michal Kurlaender.

And O’Connor recalled Powell’s assertion that diversity brings major benefits to academic settings.

“These benefits are not theoretical but real, as major American businesses have made clear that the skills needed in today’s increasingly global marketplace can only be developed through exposure to widely diverse people, cultures, ideas, and viewpoints,” she wrote.

O’Connor, who was widely considered the swing vote on Monday’s cases, also cited the example of the U.S. military. A friend-of-the-court brief filed by high-ranking members of the armed forces said their ranks had reaped advantages from diversity after putting race-conscious policies in place.

But O’Connor also diverged from Powell, citing further justifications than diversity alone.

“The present decision goes way beyond Bakke, despite its formal equivalence,” said Professor of Education Emeritus Nathan Glazer.

For instance, O’Connor insisted that transparent opportunity for minorities was a compelling reason to continue affirmative action in a breeding-ground for future leaders like Michigan Law—a rationale entirely absent from Powell’s 1978 ruling.