Just over forty years ago the Supreme Court struck down race-based quotas in school admissions while also upholding the core tenets of affirmative action. In the landmark 1978 decision, Regents of the University of California v. Bakke, Justice Lewis F. Powell, Jr., singled out Harvard’s admissions program as an exemplar for achieving diversity and applauded the university’s own description of its policy, according to which the “race of an applicant may tip the balance in his favor just as geographic origin or a life spent on a farm may tip the balance in other candidates’ cases.” As the Supreme Court would later emphasize, such review considered race merely a “factor of a factor of a factor.”