IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION
CHERYL J. HOPWOOD, DOUGLAS W. §
CARVELL, KENNETH R. ELLIOTT, §
and DAVID A. ROGERS,
§
Plaintiffs,
§
§
VS.
§ NO. A 92 CA 563 SS
§
THE STATE OF TEXAS; UNIVERSITY §
OF TEXAS BOARD OF REGENTS;
§
BERNARD RAPOPART, ELLEN C.
§
TEMPLE, LOWELL H. LEBERMANN, §
JR., ROBERT J. CRUIKSHANK,
§
THOMAS O. HICKS, ZAN W.
§
HOLMES, TOM LOEFFLER, MARIO
§
E. RAMIREZ, and MARTHA E.
§
SMILEY, as members of the
§
Board, in their official
§
capacities; UNIVERSITY OF
§
TEXAS AT AUSTIN; ROBERT M.
§
BERDAHL, President of the
§
University of Texas at Austin §
in his official capacity;
§
UNIVERSITY OF TEXAS SCHOOL OF §
LAW; MARK G. YUDOF, Dean of
§
the University of Texas
§
School of Law in his official §
capacity; STANLEY M.
§
JOHANSON, Professor of Law
§
in his official capacity,
§
Defendants.
§
MEMORANDUM OPINION
This is the continuing case of four white students who contend they were
denied admission to the University of Texas School of Law in 1992 as a result
of procedures granting preferences in admission to black and Mexican-American
applicants.
I.
On September 29, 1992, the plaintiffs Cheryl J. Hopwood, Douglas W. Carvell,
Kenneth R. Elliot, and David A. Rogers filed suit under 42 U.S.C. §§
1981 and 1983 (West 1994) and Title VI of the Civil Rights Act of 1964, 42
U.S.C. § 2000d (West 1994) ("Title VI"),[1]
No person in the United states shall, on the ground of race, color, or national
origin, be excluded from participation in, be denied the benefits of, or be
subjected to discrimination under any program or activity receiving Federal
financial assistance.
42 U.S.C. § 2000d. against the defendants the State of Texas, the
University of Texas Board of Regents, the University of Texas, the University
of Texas School of Law ("the law school"), and various University of Texas
officials in their official capacities.[2] The
plaintiffs sought injunctive and declaratory relief, as well as compensatory
and punitive damages. The Court held an eight-day bench trial in the case in
May 1994.
On August 19, 1994, the Court issued its memorandum opinion in Hopwood v.
State of Texas, 861 F. Supp. 551 (W.D. Tex. 1994) ("Hopwood I"). In
deference to controlling Supreme Court precedent, the Court declined to declare
the law school's use of racial preferences in its admissions system
unconstitutional per se, see id. at 553-54, and instead applied
strict scrutiny to the law school's admissions system, see id. at
568-69. Relying primarily on Justice Powell's opinion in Regents of the
University of California v. Bakke, 438 U.S. 265, 98 S. Ct. 2733 (1978), the
Court found that the law school's use of racial preferences for the purpose of
achieving a diverse student body served a compelling state interest under the
Fourteenth Amendment. See Hopwood I, 861 F. Supp. at 569-571.
Additionally, the Court found that the remedial nature of the admissions
process, in which racial classifications were used as a means of overcoming the
present effects of past race discrimination, served a compelling governmental
interest. See id. at 571-73. The Court ultimately concluded, however,
that the law school's use of separate admissions procedures for minorities and
nonminorities[3] was not narrowly tailored to
achieve those compelling interests because the process prevented any meaningful
comparative evaluation among applicants of different races. See id. at
573-579. The Court therefore entered declaratory judgment that the law
school's 1992 admissions procedures violated the Fourteenth Amendment. See
id. at 582.
The Court then considered whether any of the four plaintiffs was denied
admission in 1992 as a result of the constitutionally impermissible method in
which the law school considered race in its admissions procedures. In
determining which party bore the burden of persuasion on that issue, the Court
adopted a burden-shifting scheme similar to that used in employment
discrimination cases brought pursuant to Title VII of the Civil Rights Act of
1964, 42 U.S.C. § 2000e (West 1994) ("Title VII"), and placed the ultimate
burden of persuasion on the plaintiffs.[4]
See id. at 579-80. The Court found that the plaintiffs failed to
establish by a preponderance of the evidence that they would have been offered
admission to the law school under a constitutional admissions process. See
id. at 580-82. The Court therefore declined to award the plaintiffs
injunctive relief (that is, an immediate order of admission) or compensatory
damages.[5] See id. at 582-83.
Furthermore, given the undisputed remedial goals of the admissions program, as
well as the fact that the law school adopted the program in a good faith effort
to comply with federal guidelines under Title VI, the Court declined to issue
an award of punitive damages. See id. at 583. Finally, because the law
school had substantially modified its admissions procedures by the end of the
trial to provide for individual comparison among minority and nonminority
applicants (thereby remedying the infirmity identified by the Court in its
opinion), the Court declined to issue any permanent injunctive relief against
the law school. See id. at 582.
A three-member panel of the Fifth Circuit Court of Appeals reversed and
remanded the Court's decision in part in Hopwood v. State of Texas, 78
F.3d 932 (5th Cir.), cert. denied, -- U.S. --, 116 S. Ct. 2581 (1996)
("Hopwood II").[6] The Fifth Circuit
declared that the law school's use of racial preferences served no compelling
state interests under the Fourteenth Amendment.[7] See id. at 941-55. The divided Fifth Circuit panel
therefore directed the law school not to use race as a factor in admissions,
although it declined to order any permanent injunctive relief to that effect.
See id. at 958. Furthermore, the Fifth Circuit disagreed with the
Court's allocation of the burden of proof on the issue of causation--whether
any of the four plaintiffs would have been admitted to the law school under a
constitutional system. Using the burden-shifting scheme of Mt. Healthy City
School District Board of Education v. Doyle, 429 U.S. 274, 97 S. Ct. 568
(1977), the Fifth Circuit determined the law school bore the burden of proof on
that issue because the plaintiffs had successfully established the
unconstitutionality of the admissions system. See Hopwood II, 78 F.3d
at 955-57.
On remand, the Fifth Circuit directed the Court to reconsider two issues.
First, the panel directed the Court to apply the proper burden and to
reevaluate whether any of the four plaintiffs would have been admitted to the
law school in the absence of admissions procedures which took into account an
applicant's race or ethnicity. Second, the Fifth Circuit instructed the Court
to "revisit" the issue of damages in the event the law school fails to meet its
burden: "In the event that the law school is unable to show (by a preponderance
of the evidence) that a respective plaintiff would not have been admitted to
the law school under a constitutional admissions system, the court is to award
to that plaintiff any equitable and/or monetary relief it deems appropriate."[8] Id. at 957.
In accordance with the Fifth Circuit's instructions on remand, this case was
tried before the Court on March 31 and April 2, 3, and 7, 1997. Having
carefully considered the evidence presented at both trials and the arguments
and briefing of counsel, the Court finds the law school has proved by a
preponderance of the evidence that none of the plaintiffs would have been
admitted to the law school under a constitutional admissions system. In the
event any of the plaintiffs successfully appeals that decision, the Court makes
several alternative factual findings and legal conclusions regarding the issue
of damages. Finally, the Court enters its findings of fact and conclusions of
law regarding the attorneys' fees to which the plaintiffs are entitled as
prevailing parties under 42 U.S.C. § 1988 (West 1994).
II.
The admissions process employed by the law school in 1992 and the plaintiffs'
qualifications for admission are summarized here for the convenience of the
reader and to provide a context for the opinions of the defendants' expert on
causation, Professor Olin Guy Wellborn, III.[9]
In 1992, the law school received 4,494 applications for admission to fill
approximately 500 available seats.[10] See
Hopwood I, 861 F. Supp. at 563; Hopwood II, 78 F.3d at 935 n.2.
Given the rather large volume of applications it receives, the law school
devised and for several decades has used an administrative procedure by which
applicants are categorized according to their Texas Index ("TI") score. An
applicant's TI score is calculated by the Law School Data Assembly Service
("LSDAS"). It is a composite number reflecting both the applicant's grade
point average ("GPA") and score on the Law School Aptitude Test ("LSAT"), and
it is generally considered a rough predictor of one's probability of success in
law school. See Hopwood I, 861 F. Supp. at 557 n.9; Hopwood II,
78 F.3d at 935 & n.1. In 1992, the law school placed each applicant, as
dictated by his or her TI score, into one of the following three categories:
presumptive admit, presumptive deny, and the discretionary zone. See
Hopwood I, 861 F. Supp. at 558; Hopwood II, 78 F.3d at 935.
The admissions committee in 1992 comprised nine professors, two assistant
deans, and four students. Hopwood I, 861 F. Supp. at 560. Three
members of the admissions committee, Professor Stanley Johanson and Assistant
Deans Susana Alemán and Laquita Hamilton, formed a subcommittee to
review the files of minority applicants.[11]
See id. As chair of the admissions committee, Johnson had the
responsibility of setting the presumptive admission and presumptive denial
lines throughout the admissions process.[12]
See id. He set the first of several presumptive admission lines in late
January 1992 and began extending offers at that time to ensure that the most
desirable applicants received offers as quickly as possible. See id. at
561. Because the law school application deadline was not until February 1,
1992--and thus the quality of the entire applicant pool had not yet been
defined--Johanson set this initial presumptive admit line relatively high.[13] See id. at 560-61. Johanson then
reviewed the files within the presumptive admission category to determine
whether the applicant's TI score was inflated by high grades in a
noncompetitive university and/or major, or whether there was some other
questionable aspect to the applicant's file. See id. at 561. "Those
applications with a high TI reflecting a high LSAT and high grades in a
rigorous major at a leading undergraduate institution were admitted by
Johanson, who had unilateral authority to admit any applicant in this category
without further consultation with the full admissions committee." Hopwood
I, 861 F. Supp. at 561. Questionable files (roughly five to ten percent of
all presumptive admit files) were placed in the discretionary zone for further
review. See Hopwood II, 78 F.3d at 936.
Essentially the same procedure occurred at the other end of the spectrum.
Johanson set the initial presumptive denial line, and one or two members of the
admissions committee then reviewed all of the applications in this category.
See Hopwood I, 861 F. Supp. at 561. Applicants with TI scores that
understated their competitive standing relative to the rest of the pool were
upgraded to the discretionary zone. See id. Johanson testified at the
first trial that he could not recall the number of presumptive deny files that
were upgraded in 1992, although generally twenty to forty files were moved to
the discretionary zone as a result of this review. See id. The
discretionary zone, therefore, comprised "those applicants whose TIs fell
between the presumptive denial line and the presumptive admission line, those
applicants who Johanson had moved down from the presumptive admission category,
and those applicants who reviewers had moved up from the presumptive denial
category." Id.
The law school's admissions procedures treated minority applicants differently
in two ways. First, the presumptive admissions and denial lines were lower for
minorities than they were for nonminorities.[14] By March 1992, the presumptive admission line for
resident nonminorities was lowered from 202 to 199, while the presumptive
denial line was set at 192. See id. at 561-62. For Mexican-Americans,
however, the presumptive admission line was lowered from 196 to 189, and for
blacks this line was lowered from 192 to 189. For both minority groups, the
presumptive denial line was 179. See id. at 562; Hopwood II, 78
F.3d at 936. Second, minority and nonminority files within their respective
discretionary zones were segregated and subjected to different procedures of
review. The minority subcommittee was to meet as a group to review and discuss
all the minority files. Although the minority subcommittee provided the full
admissions committee with summaries of the files they considered to be good
candidates, the subcommittee's admissions decisions were virtually final.
See Hopwood I, 861 F. Supp. at 562. Nonminority applications, on the
other hand, were separated into weighted stacks of thirty files, and each stack
was reviewed by a random three-member panel of the admissions committee.[15] See id. Rather than review the
piles as a group, each member of the panel conducted an independent and secret
screening of the stack of thirty files and voted to offer admission to an
average of nine applicants from the stack.[16]
See id. Johanson then tallied the number of votes each applicant
received within his or her stack of thirty. Applicants receiving two or three
votes were offered admission, applicants receiving no votes were immediately
denied admission, and applicants receiving one vote were offered a position on
the waiting list. See id.
The plaintiffs were each reviewed by a three-member panel in the nonminority
discretionary zone screening, and all were considered Texas residents by the
admissions committee. Hopwood received an associate's degree in accounting
from Montgomery County Community College in 1984, and she earned a bachelor's
degree in accounting from California State University-Sacramento in 1988. She
graduated with a GPA of 3.80 and had an LSAT score in the 83rd percentile.[17] See Hopwood I, 861 F. Supp. at 564;
P-145. Although Hopwood had a TI score of 199 which, by March 1992, placed her
just within the presumptive admit line, Johanson concluded her GPA overstated
her educational background and therefore downgraded her file to the
discretionary zone. See id. at 564. Carvell, Elliot and Rogers each
had a TI score of 197. Carvell attended Hendrix College in Conway, Arkansas,
where he graduated with a bachelor's degree in political science in 1991. He
had a GPA of 3.28 and an average LSAT score in the 76th percentile.[18] See id. at 566-67; P-151. Elliot
graduated with a bachelor's degree in accounting from the University of Texas
in 1984, where he earned a GPA of 2.98, and he scored in the 95th percentile on
the LSAT. Following graduation, he became a certified public accountant
("CPA") and worked for various state agencies in Texas as an auditor or
examiner. See id. at 565-66, P-153. Rogers earned an undergraduate
degree in professional writing from the University of Houston-Downtown in 1990.
In the early to mid-1980s, he attended the University of Texas, where he was
placed on academic probation once and dismissed twice for poor scholastic
performance. He had a cumulative GPA of 3.13 and an LSAT score in the 94th
percentile. Rogers earned a master's degree in professional writing from the
University of Southern California in 1992. See Hopwood I, 861 F. Supp.
at 567; P-171. By contrast, the median GPA for white students in the 1992
entering class was 3.56, and the median LSAT score was in the 91st percentile.
See Hopwood II, 78 F.3d at 936-37 & n.7. For all students (minority
and nonminority) in the 1992 entering class, the median GPA was 3.52, while the
median LSAT score was in the 89th percentile. See id.
Hopwood and Carvell each received one vote in screening, were offered
positions on the waiting list, and were eventually denied admission to the law
school in Spring 1992. See Hopwood I, 861 F. Supp. at 564-66. Elliot
and Rogers received no votes in screening and were immediately notified of
their rejection in April 1992.[19]
See id. at 565-67. By the end of the admissions process, the law school
had extended offers to 936 resident and nonresident applicants. See id.
at 563 n.32. Of the 637 offers extended to Texas residents, 96 went to blacks
and Mexican-Americans and 541 went to whites and nonpreferred minorities.
See D-519. The plaintiffs were therefore among over 3,500 individuals,
including approximately 1,500 Texas residents, who were denied admission to the
law school in 1992.
III.
The Fifth Circuit characterizes Mt. Healthy as devising "a
test of 'causation' that place[s] the burden of proving no harm on the
defendant" when the plaintiff establishes the defendant intended to
discriminate or otherwise acted unconstitutionally. See Hopwood II, 78
F.3d at 956. The Court respectfully suggests that the Mt. Healthy
framework is inapplicable to this case and the plaintiffs should retain the
burden of proof. In Mt. Healthy, an untenured teacher claimed a school
board's decision not to rehire him was the result of the comments he had made
on a radio show. See Mt. Healthy, 429 U.S. at 281-3, 97 S. Ct. at
573-74. Although the board conceded the comments had influenced its decision
not to rehire the teacher, the board asserted the teacher would not have been
rehired in any event because of legitimate, nondiscriminatory reasons unrelated
to the exercise of his First Amendment rights.
The district court found that the teacher's comments were protected by the
First Amendment and that they played a "substantial part" in the board's
decision not to rehire him. See id. at 283, 97 S. Ct. at 574.
The district court ordered the teacher's reinstatement, which ultimately
resulted in his receiving tenure, and the circuit court affirmed the trial
court's findings and conclusions. See id. at 283-86, 97 S. Ct. at
574-75. Mt. Healthy was unique in that it presented the Supreme Court
with a "mixed motives" case in which the governmental entity admitted it
considered both legitimate and illegitimate factors in reaching its employment
decision, in contrast to the typical "pretext" case in which the only issue is
whether any improper or discriminatory motive exists.[20]
Therefore, the question
before the Supreme Court was whether the plaintiff had necessarily shown a
constitutional violation justifying remedial action simply by establishing that
the protected conduct was a "substantial" factor in the board's decision not to
rehire him. See id. at 285, 97 S. Ct. at 575. The Supreme Court
answered that question in the negative. The Supreme Court reasoned that
allowing a plaintiff to recover under those circumstances might "place the
employee in a better position as a result of the exercise of constitutionally
protected conduct than he would have occupied had he done nothing," because it
would require holding the defendant liable even though the same employment
decision would have been made for entirely legitimate reasons. Id. In
response to this dilemma, the Supreme Court devised a burden-shifting framework
in which the plaintiff initially bears the burden of proving that the
constitutionally protected conduct was a "substantial" or "motivating" factor
behind the employer's discriminatory action. See id. at 287, 97 S. Ct.
at 576; Village of Arlington Heights v. Metropolitan Housing Dev. Corp.,
429 U.S. 252, 270 n.21, 97 S. Ct. 555, 566 n.21 (1977) (characterizing the
plaintiff's burden as a "required threshold showing"). Only after the
plaintiff makes this showing does the burden then shift to the defendant to
prove that the violation was "largely harmless." See Hopwood II, 78
F.3d at 957. Therefore, unlike the McDonnell Douglas framework used in
Title VII pretext cases (in which the burden of persuasion remains on the
plaintiff at all times), the burden of persuasion shifts to the defendant in
mixed-motives cases once it is either conceded by the defendant or determined
by the fact finder that the employer considered impermissible factors in
reaching its adverse employment decision. Mt. Healthy therefore
confirms the rather uncontroversial proposition that plaintiffs are required to
prove injury-in-fact in order to collect monetary damages. See Mt.
Healthy, 429 U.S. at 285, 97 S. Ct. at 575.
Unlike the adverse employment action at issue in Mt. Healthy, there are
two types of injury in a case involving the unlawful use of racial preferences.
As the Court recognized in Hopwood I, 861 F. Supp. at 583, there is an
intangible injury resulting from the government's discriminatory classification
which prevents a plaintiff from "competing on an equal footing" with other
applicants.[21]See Hopwood II, 78 F.3d at 957 (quoting Adarand
Constructors, Inc. v. Peña, 515 U.S. 200, 211, 115 S. Ct. 2097, 2105
(1995)). All nonminorities who applied to the law school in 1992, including
nonminority students who were admitted, suffered that kind of injury. A
second, tangible type of injury--an injury-in-fact--occurs when a plaintiff is
actually denied some right or benefit, such as admission to the law school, as
a direct result of the use of unlawful racial preferences. In applying the
Mt. Healthy framework to this case, the Fifth Circuit affirmed this
Court's conclusion that the law school's 1992 admissions procedures were
constitutionally flawed. With virtually no explanation, however, the Fifth
Circuit then asserted that, as a result of that determination alone, the
defendants bear the burden of proving that the constitutional violation against
the four plaintiffs was "largely harmless." See Hopwood II, 78 F.3d at
957 ("In this case, there is no question that a constitutional violation
occurred (as the district court found) and that the plaintiffs were harmed
thereby."). The Fifth Circuit's analysis in this regard was incomplete at
best; at worst, it was a misapplication of the Mt. Healthy framework
because it presupposed that race was a substantial or motivating factor in
every nonminority applicant's denial of admission to the law school in 1992,
regardless of the applicant's qualifications to enter law school. As a matter
of common sense and rudimentary mathematics, that cannot be the case.
There is no basis in fact or logic to suggest, as the Fifth Circuit apparently
does in Hopwood II, that all resident nonminority applicants who were
denied admission to the law school in 1992 were denied admission
substantially--or, for that matter, even in small part--because of race. Even
assuming all 96 offers of admission made to resident minorities in 1992 were
available, there would still remain approximately 1,400 resident applicants in
1992 (the overwhelming majority of whom, presumably, were nonminorities) who
would have been denied admission without regard to race. At most, therefore,
only 7% of resident nonminority applicants were affected by the law school's
use of racial preferences.[22] Suppose this
case had been brought by the least qualified nonminority who applied to the law
school in 1992. Under Adarand, that applicant clearly would have
standing to challenge the affirmative action program. See Adarand, 515
U.S. at 212, 115 S. Ct. at 2105. However, an applicant who has no conceivable
chance of admission cannot possibly show that race was a substantial or
motivating factor in the law school's decision to deny him or her admission.
The Mt. Healthy burden-shifting framework is never implicated. In
contrast, Hopwood II always shifts the burden to the defendant--and
would shift the burden even in the example of the candidate with no chance of
admission--once the plaintiff establishes the unconstitutionality of the
affirmative action program. But being subjected to admissions procedures that
take into account racial preferences does not, in and of itself, establish or
even imply that the applicant's race was a substantial or motivating factor in
his or her denial. Importantly, in this case the law school, unlike the
University of California in Bakke, never conceded that the plaintiffs
would have been admitted in the absence of an affirmative action program, and
this Court specifically found the plaintiffs failed to carry their burden of
persuasion on that point. See Hopwood I, 861 F. Supp. at 581-82.
The harm in the Fifth Circuit's interpretation of Mt. Healthy is not
readily apparent in the Court's example because it would be quite easy for the
law school in that instance to establish the applicant's non-admission. The
harm occurs, for example, when the suit is brought by a candidate who has some
chance of admission under a race-neutral procedure but who would not be able to
prove that he or she would have been admitted by a preponderance of the
evidence. The Fifth Circuit decision potentially gives those candidates a
windfall by placing the ultimate burden of proof on the defendant: close calls
must always be decided in favor of the plaintiff. And yet the function and
purpose of the Mt. Healthy burden-shifting scheme are just the
opposite--to ferret out instances of discrimination and to ensure that the
plaintiff is not put in a better position than he or she ordinarily would have
occupied. Indeed, the Fifth Circuit recognized in Hopwood II that
Mt. Healthy was intended to give the defendant "a second chance of
prevailing by showing that the violation was largely harmless." See Hopwood
II, 78 F.3d at 957. Instead of giving the defendant a second chance of
prevailing, the Fifth Circuit gives the defendant little chance of prevailing
when the applicant is an extremely close call. The Fifth Circuit decision
essentially allows a plaintiff to recover monetary damages without ever having
to establish any injury-in-fact.[23]
Mt. Healthy does not apply to this case. One might be able to make a
normative argument that the defendants should bear the ultimate burden of
persuasion once the plaintiffs establish the unconstitutionality of the law
school's affirmative action program, but the legal argument cannot be
justified. This is a classic pretext case in which the trier of fact--in this
case, the Court--must determine why each of the four plaintiffs was denied
admission to the law school. If the plaintiffs were denied admission because
of their race, they should have to prove it, as plaintiffs must in every other
pretext case brought in federal and state court. The Court therefore
respectfully but strenuously objects to this portion of the Fifth Circuit
opinion. The Court is cognizant, however, of the panel's instructions on
remand, and it will faithfully and responsibly execute them.
A.
The defendants presented one expert on causation, Olin Guy Wellborn, a tenured
professor who has taught at the law school since 1974.[24] Wellborn has served on the law school admissions
committee for over 15 years and was a member of the admissions committee in
1992. In accordance with the Fifth Circuit decision, Wellborn analyzed whether
the plaintiffs would have been admitted to the law school under a
constitutional admissions system. See Hopwood II, 78 F.3d at 957 &
n. 55. In preparation for his expert reports, Wellborn testified he carefully
examined the LSDAS sheets of approximately 450 applicants, including the LSDAS
sheets of the 96 minorities admitted in 1992. Wellborn, vol. 1 at 45.
He then narrowed the field to approximately 200 of the "most promising"
minority and nonminority candidates, as reflected by their LSDAS sheets, and he
reviewed those application files in their entirety. Id. Wellborn
prepared two expert reports, employing a different methodology in each one.
See D-519 and D-520. In both reports he concluded that none of the
plaintiffs would have been admitted in a race-blind admissions procedure.
See id.
(1) Wellborn's First Report
In his first report, Wellborn examined the 1992 admissions process and then
considered how that process would have been modified in a manner that would
yield the same total number of admissions on a race-blind basis. Wellborn
first compared the relation between an applicant's TI score and the statistical
rate of admittance in the actual 1992 admissions process. Wellborn detected
the emergence of a pattern in which candidates with TI scores of 203 or higher
were virtually all admitted and candidates with TI scores of 184 or lower were
virtually all denied. A discretionary zone candidate's statistical chance of
admittance generally increased by an additional 10 or 20 percentage points with
each successive TI score.[25]
Hopwood's TI score of 199 corresponded to an acceptance rate of 89%, and a TI
score of 197 (the TI score belonging to Carvell, Elliot, and Rogers)
corresponded to an acceptance rate of 59%. This pattern of percentages
reflected a typical, yearly phenomenon.[26]
See Wellborn, vol. 1 at 145.
Because the actual 1992 presumptive admission and denial lines were lower for
minorities than for nonminorities, Wellborn had to adjust the overall
presumptive admission and denial lines in creating a hypothetical admissions
system.[27] Wellborn therefore lowered the
overall presumptive admit and deny lines to 198 and 190, respectively, and
retained the 1992 average of nine votes per pile of thirty files. Wellborn
assumed the law school would extend the same number of resident offers that it
had extended in 1992.[28] See D-520;
Wellborn, vol. 1 at 237. Using this methodology, Wellborn predicted a
pattern of percentages in admissions almost identical to the 1992 admissions
percentages, except that each percentage of admission would be "notched down"
by one TI score throughout. In other words, Wellborn predicted that virtually
all candidates with a TI score of 202 and above would have been admitted; 90%
of applicants with TI scores ranging from 198 to 201 would have been admitted;
70% of applicants with TI scores of 197 would have been admitted, and so on
down the Texas Index.[29]
Wellborn then reexamined the application
files of the four plaintiffs, the admitted minority resident applicants, and
the denied nonminority resident applicants at their respective TI scores to
determine who would have received the additional offers as dictated by the
predetermined percentages of admission.
Wellborn predicted that one additional offer of admission would be made at
Hopwood's TI score. Of the ten admitted minority and denied nonminority
resident applicants at the 199 TI level, Wellborn concluded that seven
applicants, including the four minority applicants, were "clearly stronger"
than Hopwood and that the remaining two applicants were "comparable" to
Hopwood. As in the actual admissions process in 1992, Wellborn determined that
Hopwood would most likely have been placed in the discretionary zone by
Professor Johanson and that she would not have received the two or three votes
necessary to be admitted. At the 197 TI score of Carvell, Elliot, and Rogers,
Wellborn estimated that the law school would have extended seven additional
offers.[30] Wellborn identified the seven
applicants he predicted would have been offered admission over Carvell, Elliot,
and Rogers, and he also rated those seven applicants superior to Hopwood.
Wellborn then identified four additional applicants who, although not as strong
as the original seven, were still stronger than Carvell, Elliot, and Rogers.
Indeed, Wellborn indicated that Rogers and Elliot were "among the very weakest"
at that index and that Carvell, although a stronger applicant than Elliot and
Rogers, does not compare favorably because of his relatively low combined LSAT
score in the 76th percentile.[31] See
D-519.
(2) Wellborn's Supplemental Report
Using his first report as a hypothesis for how the law school would have
extended offers of admission in a race-blind procedure, Wellborn undertook the
more difficult task in his supplemental report of specifically identifying (1)
the admitted resident minorities in 1992 who probably would have been denied
admission in a race-blind procedure, and (2) the denied resident nonminority
applicants who most likely would have been admitted in their place. Wellborn
made several basic assumptions about a hypothetical race-blind admissions
procedure. First, as he had in his first report, Wellborn projected that the
presumptive admission line would be set at 198 and that the presumptive denial
line would be set at 190. He then assumed that all of the nonminority
residents who had been admitted in 1992 would have been admitted in a
hypothetical race-blind admissions procedure. Therefore, Wellborn only
examined the application files of the 96 admitted minority applicants and the
approximately 450 LSDAS reports (which he then narrowed down to about 200
application files) of the denied residents (minority and nonminority) who had
TI scores above 190.[32] See D-520;
Wellborn, vol. 1 at 45. In examining each application, Wellborn
primarily considered the applicant's college record and LSAT score, which he
weighed "about equally,"[33] and he applied
identical standards to minority and nonminority candidates. See D-520.
In evaluating the college record, he considered the caliber of the school, as
manifested by the LSAT college mean,[34] and
the applicant's major, rank in class, and college transcript. Wellborn also
considered an applicant's personal statement, letters of recommendation, and
other factors and materials such as the applicant's age and background; the
relevance and importance of these factors varied, of course, with each file.
In selecting a particular applicant for his supplemental report, Wellborn
attempted to predict those candidates who he believed would emerge as probable
admittees. He did not, in other words, only select candidates for whom he
necessarily would have voted, nor did he attempt to predict how a particular
admissions committee member would have voted. See Wellborn, vol. 1 at
231-33, 249-51. Wellborn explained his approach as follows:
[I]f I say these candidates are the ones that I judge most likely to be
admitted, and these I judge to be relatively unlikely to be admitted, that's
not going to describe in exact detail the offers that go out. I'm making an
overall estimate of probabilities, based upon many years of experience in
watching this process and having a judgment about on the average which criteria
are going to be most influential and most important to the reviewers as a
group. And so, of course, there are going to be those vagaries in the voting,
but I still believe in the overall validity of the prediction.
It certainly is not the case--absolutely is not the case that . . . [all]
denied non-minorities [within the discretionary zone] . . . have an equal
chance [of admission] . . . or that a person, as familiar as I am with the
process, couldn't tell you that these people have a better chance than these
other people. I think . . . it would be preposterous to suggest that . . .
it's just random, or that it's completely unpredictable.
Wellborn, vol. 1 at 250.
The law school made 96 offers of admission to resident minorities in 1992.
Wellborn evaluated all 96 minority admittees and concluded that 19 would have
been admitted without regard to race. Wellborn named this group of applicants
"Group A." Wellborn then selected 2 additional resident minority admittees
who, though weaker than the original 19, would still have a better chance of
admission than any of the plaintiffs in a color-blind procedure ("Group B").
Subtracting the Group A applicants from the actual number of resident minority
admittees in 1992 leaves 77 seats remaining for nonminority resident applicants
who were denied in 1992. There were 398 nonminority residents with TI scores
of 190 or above who were denied admission in 1992; therefore, fewer than 20% of
candidates in Wellborn's hypothetical discretionary zone would have been
offered admission. Of those 398 files, Wellborn selected 78 resident
nonminority applicants[35] who he believed
probably would have been offered admission in a race-blind procedure ("Group
C"). As with the minority applicants reflected in Group B, Wellborn also
selected an additional 20 resident nonminority applicants who he believed had a
reasonable chance of admission as alternatives to the Group C candidates
("Group D").[36] Wellborn testified that none
of the plaintiffs merited inclusion in either Group C or D. See
Wellborn, vol. 1 at 115.
The plaintiffs have several objections to the methodology Wellborn used in his
supplemental report.[37] First, the
plaintiffs argue the random admissions procedure employed in 1992 effectively
prevents the defendants from carrying their burden of proving that the
plaintiffs would not have received offers of admission in a race-neutral
procedure. Second, Hopwood and Carvell argue that, in contravention of the
Fifth Circuit decision, Wellborn made no attempt to reconstruct the actual
admissions process used in 1992 to determine which nonminority residents would
have been offered admission under a constitutional system, nor did he devise a
methodology revolving around either the piles of thirty or the waiting list
actually generated in 1992. Third, the plaintiffs criticize Wellborn for
making the assumption that all nonminority residents who were given offers of
admission in 1992 would nevertheless have been admitted under a constitutional
system. Fourth, Hopwood and Carvell argue that Wellborn's testimony is
insufficient to carry the defendants' burden as a matter of law because
Wellborn relied on "mere statistical likelihoods" in concluding that the four
plaintiffs would have been denied admission under a race-neutral system. The
Court considers each objection seriatim.
As this Court recognized in Hopwood I, reconstructing the actual 1992
admissions procedure is a conceptually difficult, if not "virtually
impossible," task: "[T]he difficulty does not stem from the unconstitutional
aspects of the procedure alone but from the random shuffle of files into stacks
of thirty, each stack reviewed by different subcommittees of three."[38]
Hopwood I, 861 F. Supp.
at 582 n.86. Although the stacks were weighted as closely as possible with the
same number of high to low TI scores, see Wellborn, vol. 1 at 41, an
applicant's chances for admission may in some instances have depended upon the
personal tastes of the reviewers who evaluated the applicant's file and whether
the applicant was placed in a stack with an unusually strong or weak pool of
applicants. To the extent that the plaintiffs argue that the admissions
procedure used in 1992 was inherently unfair due to the random composition of
the piles of thirty and the subjectivity of each reviewer, the point is very
well taken. It goes without saying, however, that this unfairness does not
implicate a constitutional defect with the law school's admissions procedures.
To the extent that the plaintiffs argue that the law school can never meet its
burden for that reason, the point is not well taken. A particular applicant's
admission to the law school in 1992 was not the result of a random and
unpredictable process--after all, applicants were not admitted by a flip of a
coin. And it is nonsense to suggest that all nonminorities who were denied
admission in 1992 would have an equal chance of admission under a race-blind
procedure. With or without the law school's ill-advised piles-of-thirty
approach, even a superficial comparison of the four plaintiffs, for instance,
reveals the varying quality of students who applied to the law school in 1992
and confirms that concrete distinctions can be made among those applicants--if
not to a virtual certainty, then at least by a preponderance of the
evidence.
The plaintiffs' argument that Wellborn should have reproduced an admissions
procedure by which application files were randomly placed into piles of thirty
and then reviewed by randomly formed screening committees is also without
merit. Wellborn is a very talented law professor, but he cannot turn back the
hands of time, nor does the Fifth Circuit decision require him to do so.
Rather, the inquiry posed by the Fifth Circuit is whether any of the four
plaintiffs would have been admitted under "a constitutional admissions
system." See Hopwood II, 78 F.3d at 957 (emphasis added). The Court,
therefore, does not read the Fifth Circuit opinion as instructing the
defendants to replicate exactly the 1992 admissions procedure or to use the
1992 piles-of-thirty approach. First, how would one go about reproducing a
random process? By the very definition of the word random, it cannot be done.
The only logical, reasonable, and fair way to determine who would have received
offers of admission under a constitutional system is to compare the application
files of all of the admitted minorities and the denied nonminorities, and that
is precisely the methodology Wellborn used in his supplemental report.[39] Furthermore, using the 1992 piles of thirty
would perpetuate the unconstitutional aspects of the 1992 admissions procedure.
The admissions procedure employed in 1992 was fraught with constitutional error
precisely because the original piles of thirty did not include any minority
applicants. Those piles would never exist under a constitutional admissions
system, and as a result, it would make no sense to use them now to determine
whether any of the plaintiffs would have gained admission to the law school in
1992. The Court finds it more than a little baffling that the plaintiffs
assert Wellborn should have utilized, as the very premise of his methodology,
the admissions system found unconstitutional as a result of this lawsuit.
Likewise, using the 1992 waiting list to determine who would have been
admitted under a constitutional system is equally problematic. In support of
this method, Hopwood and Carvell argue that the one vote they actually received
in 1992 placing them on the waiting list is more probative than any subsequent
attempt to reconstruct a hypothetical race-blind admissions process. While
this method certainly has some intuitive appeal, it is not the best way to
determine which nonminority applicants would have gained admission in 1992 in a
race-blind procedure. First, there were two waiting lists in 1992, each of
which was segregated by race. See Hopwood I, 861 F. Supp. at 574 n.68.
Second, this methodology suffers from the same defect identified with respect
to the original piles of thirty: the waiting list was generated by an
unconstitutional system in which minority and nonminority applicants were
reviewed separately. Therefore, the waiting list created in 1992 would not
exist under a constitutional admissions system. Third, due to the change in
the LSAT scoring system, 1992 was somewhat of an anomaly in that the law school
had not extended a sufficient number of offers through its normal procedures.
As a result, the admissions committee had to select an unusually high number of
candidates--42 out of 123 applicants--from the waiting list.[40] See Wellborn, vol. 1 at 52-53, 144. Wellborn
testified that the waiting list had been pretty well "picked over" and,
consequently, the remaining eighty-one applicants on the waiting list had, in a
sense, a third "no" vote denying them admission.[41] See Wellborn, vol. 1 at 52-54. Fourth, using the
waiting list to determine who would have gained admission is, in the Court's
opinion, self-defeating for all of the plaintiffs: the methodology would
unfairly exclude Elliot and Rogers from consideration because they received no
votes in screening, and the one vote Carvell and Hopwood each received is not
necessarily probative of any increased likelihood that they would have been
admitted in a race-blind procedure. Carvell's vote was from a student member
of the admissions committee, not a faculty member, see Hopwood I, 861 F.
Supp. at 566, and Hopwood's vote was essentially a "sympathy vote" from
Hamilton, then the Assistant Dean of Admissions for the law school.[42]
The plaintiffs also argue that Wellborn arbitrarily and impermissibly "picks
and chooses" among actual events in 1992 in that he (1) gave no weight to
applicants who were placed on the waiting list by virtue of their one vote and
(2) assumed that all nonminority applicants who were admitted in 1992 would
have been admitted in a race-blind procedure. The plaintiffs urge the Court to
disregard Wellborn's supplemental report entirely because, they argue, he did
not reconsider all offers of admission in hypothesizing a constitutional
admissions system. Not only is this argument unpersuasive, it mischaracterizes
Wellborn's methodology. The plaintiffs acknowledge it was more difficult for
nonminorities to achieve offers of admission in 1992; indeed, the plaintiffs
brought this lawsuit for that very reason. The fact that those nonminority
applicants received offers of admission under the University's admissions
program is very strong evidence to support the inference that they would emerge
as probable admittees under a race-neutral system. See Wellborn, vol. 1
at 42. Wellborn did not, therefore, arbitrarily pick and choose among real
events in 1992; rather, he drew logical inferences based upon the admissions
procedure in force in 1992. The fact that an applicant was presumptively
admitted, received two or three votes in the screening process, or was an
applicant chosen from the waiting list in 1992 correlates with a strong
likelihood that the applicant would have been admitted in a race-blind
admissions procedure; for the reasons indicated above, however, there is not a
sufficiently strong correlation between receiving a position on the waiting
list and an increased probability of admittance.[43] Therefore, the distinction between nonminority admittees
and waiting list candidates is warranted. Furthermore, it is conceptually
difficult to see the harm in the inference--to the extent that these
individuals were offered admission over the four plaintiffs, it certainly was
not the result of any unlawful or invidious discrimination.
Finally, the Court rejects the plaintiffs' argument that Wellborn relied on
"mere statistical likelihoods" in concluding that the four plaintiffs would
have been denied admission. In support of this argument, the plaintiffs cite
Smith v. Rapid Transit, Inc., 317 Mass. 469, 470, 58 N.E.2d 754, 755
(1945), a case in which the Massachusetts Supreme Court held it is insufficient
as a matter of law to prove a proposition merely by showing the mathematical
chances favor the veracity of the proposition. This argument might have been
valid had Wellborn conclusorily asserted, for instance, that Carvell would not
have been admitted to the law school based solely on the fact that his "true"
TI score of 191 or 192 correlated to a 5% to 15% probability of admission in
1992. But Wellborn did not use mathematical probabilities to prove Carvell
would not have been admitted to the law school under a constitutional system.
Instead, Wellborn evaluated Carvell's application according to certain
enumerated and, to a large extent, quantifiable criteria, compared his
application to the applications of 450 other denied nonminorities, and
concluded that Carvell was less qualified than the 119 applicants chosen for
inclusion in his supplemental report. See D-520. Based on the
applications in evidence, as well as his knowledge of the law school's
admissions procedures, it was Wellborn's considered opinion that it was more
likely than not that Carvell would not have been admitted to the law school
under a race-neutral admissions system. Indeed, Wellborn reached the same
conclusion with respect to the other three plaintiffs despite the fact that
their relatively high TI scores correlated with a probability of admittance of
greater than 50%. This objection is nugatory.
The Court therefore concludes that the methodology Wellborn employed in his
supplemental report is sound. Wellborn did not attempt to handicap the chances
of admission of each and every applicant who was denied admission to the law
school in 1992. Rather, Wellborn presented evidence of 119 applicants who were
better candidates for the study of law than the plaintiffs and who were
therefore more likely to receive offers of admission under a constitutional
system. In hypothesizing a constitutional admissions system, Wellborn made
reasonable projections regarding the lowering of the presumptive admission and
denial lines and the probable number of offers to be extended. His assumption
that all nonminority resident admittees in 1992 would be admitted under a
race-neutral system is not only reasonable but supported by the record.
Finally, Wellborn identified reasonable criteria to evaluate the application
files, and as discussed below, he applied the criteria in a fair, consistent,
and nondiscriminatory way.
C.
Before Wellborn's conclusions are explored and explained, the Court offers the
following disclaimer. This opinion provides more information than anyone ever
needed or wanted to know about the qualifications required for admission to the
law school. The Court once again undertook a painstaking review of the
application files of hundreds of students, and, unfortunately, this opinion
reflects the tedious and arduous process that it was. One principle the Court
emphasized in its first opinion bears repeating here:
[T]he Court appreciates the difficulty of the task facing the admissions
committee each year. Evaluation of applications involves both objective and
subjective factors, and the Court is aware that some evaluators could use
subjectivity to conceal discriminatory motives. As a general rule, however,
judges are not as well suited to evaluate qualifications of applications as
those who are familiar with the process and have many years of experience
evaluating applications.
See Hopwood I, 861 F. Supp. at 581 (citing Odom v. Frank, 3 F.3d
839, 847 (5th Cir. 1993)).
The plaintiffs openly accused Wellborn of manipulating certain criteria and of
disingenuously using the subjectivity of the admissions process to rig the
desired outcome of this case. The Court emphatically finds that allegation to
be false. The fact that subjective criteria necessarily informed Wellborn's
analysis does not render Wellborn's opinions arbitrary or untenable. Part of
Wellborn's everyday responsibilities as a law professor is to make subjective
assessments of students, whether on a law school exam or as a member of the
admissions committee, and the Court will not cavalierly disregard the
conclusions Wellborn reached in his supplemental report simply because they
involve subjective judgments. Furthermore, Wellborn credibly supported the
applicants he selected, and the faculty members who originally reviewed the
plaintiffs' files in 1992 universally support Wellborn's judgment that the four
plaintiffs were weak candidates for admission to the law school in 1992.
See Johanson Declaration D-332; Declaration of Laquita Hamilton
D-333; Sharlot Declaration D-334; Declaration of Mark Gergen
D-335; Goode Declaration D-336.
Before delving into the specific weaknesses of each plaintiff's application,
the Court makes the following observations and generalizations. First, TI
scores are, to a certain degree, inherently unreliable because they do not
weigh the student's GPA by major or quality of school. For example, Hopwood's
GPA of 3.80, with her high number of hours from community colleges and
subsequent transfer to a relatively weak undergraduate institution, does not
compare favorably with a student having a lower GPA from, say, Rice, Trinity,
the University of Texas, or Texas A&M. Wellborn's evaluation of Carvell's
chances for admission also illustrates the artificial nature of the Texas
Index. Although Carvell's "true" TI score was 191 or 192, Wellborn rated
Carvell "roughly comparable" to Hopwood, "slightly better" than Elliot, and
"significantly better" than Rogers. See Wellborn, vol. 1 at 117. Large
institutions such as the University of Texas use TI scores to make general
distinctions among the many students who apply. But a TI score is only as good
as its two components--the student's GPA and LSAT score. They are not
hard-and-fast numbers determining who is admitted, nor should they be treated
as such, because to do so would unfairly reward students who attended weak
undergraduate institutions or who took less-than-challenging curricula. In
light of the fact that TI scores are not weighted by quality of school or
difficulty of major, it is not surprising that the plaintiffs' relatively high
TI scores significantly overstate their chances for admission to the law school
and that Wellborn's selections ran the gamut from high to low TIs.
Second, the law school admissions process is incredibly competitive. See
Hopwood II, 78 F.3d at 935. In fact, the Court was astonished to discover
the number of applicants with drastically better credentials than the four
plaintiffs who were denied admission in 1992. For instance, of the 78
nonminority Group C applicants Wellborn selected, 31 were in the top quarter of
their classes at competitive universities such as the University of Texas and
Texas A&M and had LSAT scores in the 80th percentile and above. See
D-543, 550-51, 555, 557, 560-63, 565, 568, 570, 572-73, 576-77, 580, 582,
584-85, 587-89, 591-93, 599, 609, 611, 613, and 619. Over one third of
Wellborn's Group C selections had a college class rank in the 80th percentile
or higher; unlike Hopwood, however, these applicants attended competitive
schools and, except for one applicant, had few, if any, hours from a community
or junior college. See D-543, 551, 556, 558-60, 562, 564-68, 572,
574-76, 578-84, 609, and 611. Applicants similar to Carvell who had a class
rank below the 70th percentile virtually all came from colleges with an LSAT
mean of 34 or better such as Duke, Cornell, Rice, Tufts, and the University of
Texas, and their LSAT scores in all cases were better--and in most cases were
considerably better--than Carvell's combined LSAT score in the 76th percentile.
See D-542, 544-45, 547-49, 552, 554, 569, 594-98, 602-03, 614-15, and
618. Moreover, of the 97 Group A and C applicants Wellborn predicted would
have been probable admittees under a constitutional system, only 2 graduated in
the bottom half of their classes, as did Elliot. One applicant earned an LSAT
score in the 99th percentile and graduated in the 31st percentile of the class
at the University of California at Berkeley, a 36 LSAT mean college.
See D-524. The other applicant attended the University of Texas,
majored in a rigorous liberal arts honors program called Plan II, was in the
48th percentile of the class, and earned an LSAT score in the 96th
percentile.[44] See D-529. Wellborn
did not select a single applicant who, like Rogers, had been dismissed from a
four-year university or who had graduated from a university with an LSAT
college mean as low as that of the University of Houston-Downtown.
Third, the applicants Wellborn selected for inclusion in Groups A, B, C, and D
have superior credentials to the four plaintiffs even when one looks
exclusively at a combination of objective factors. After making his 119
selections, Wellborn discovered that his selections tended to satisfy the
following four criteria: each applicant (1) had an LSAT score in the 80th
percentile or higher; (2) had a rank in class in his or her university of at
least the 60th percentile; (3) graduated from a college with an LSAT mean of at
least thirty; and (4) had no more than one year in a community or junior
college. None of the plaintiffs satisfies all four criteria, while the vast
majority of Wellborn's selections do. Moreover, applicants who did not comply
with all four criteria counterbalanced that weakness with a specific strength.
For instance, five applicants in Group C have LSAT scores in the 78th
percentile, and three applicants in Group A and one applicant in Group D have
LSAT scores in the 74th percentile. Across the board, however, these
applicants had exceptionally strong college records at high quality
institutions.[45] Likewise, applicants with
low class ranks offset that weakness with strong LSAT scores coupled with very
competitive universities and/or particularly rigorous majors such as
engineering.[46]
Fourth, the inherently subjective nature of the admissions process does not,
as the plaintiffs contend, provide a reason to believe that distinctions cannot
be made among different applicants. Of course, reasonable minds can and do
differ on the quality of particular institutions or courses of study. For
instance, whether accounting is a more rigorous major than political science,
economics, or English is, to the Court's chagrin, an issue of raging debate
among the parties in this case. In the Court's opinion, all four courses of
study provide a good background for the study of law, and the Court, like
Wellborn, tended to focus more on the overall quality of the applicant's
undergraduate institution and curriculum in evaluating the application files.
And, the plaintiff's protestations to the contrary, Wellborn's opinion
regarding the quality of certain universities is not entirely subjective. He
supported his assessment of each institution with an objective criterion, the
LSAT college mean.[47] Cf. P-414
(discretionary zone screening instructions stating that "[t]he LSAT college
mean should be used as a general indicator of the strength of the undergraduate
institutions' student body" and indicating that reviewers should "'watch out'
for inflated GPA's due to community or junior college grades"). Even without
such quantifiable data supporting his assessments, the Court is confident
Wellborn can fairly evaluate the quality of colleges and universities around
the nation given his twenty-three years as a law professor and fifteen years on
the admissions committee. In addition, Hopwood, Carvell, and Rogers do not
appear to object to Wellborn's use of the LSAT college mean as a legitimate
means of distinguishing among universities or, significantly, to the resulting
inference Wellborn draws that the applicant's GPA is inflated. Instead, they
argue that Wellborn exaggerates the importance of this criterion. The Court
finds that argument unpersuasive. One of Wellborn's constant themes throughout
his testimony was the notion that the applicant be exposed to a "rigorous
testing ground" to prepare him or her for the study of law at an elite law
school. See, e.g., Wellborn, vol. 1 at 84. The evidence
establishes an applicant's undergraduate institution can be of paramount
importance in determining admission, particularly when the student attended a
very weak school.
On the other hand, Hopwood and Carvell also criticize Wellborn for failing to
give greater weight to or for unevenly evaluating subjective and nonacademic
factors such as post-graduate work experience, good personal statements, and
improvement in grades over time.[48] First,
some of these factors, such as improvement in grades and working through
school, are "very common," see Wellborn, vol. 1 at 68, and/or are
generally not given much weight, see Goode Declaration, D-336.[49] Second, although these kinds of subjective
factors tended to support Wellborn's assessment of a particular applicant,
see Wellborn, vol. 1 at 249, they did not appear to impact Wellborn's
selections significantly except in one unusual case.[50] See D-538. Indeed, Wellborn testified that, with
respect to marginal candidates in particular, members of the admissions
committee tend to focus primarily on an applicant's balanced and consistent
college performance and LSAT:
In general, I think we are talking here about the margin. . . . The
unimpeachable candidates have already been admitted. I'm not asserting that
these files I've selected are without fault or without weaknesses. It's a
matter of relative weaknesses . . . .
[I]t's a question, I think, of minimizing risk that over my years on the
committee what I see members doing at this margin is looking for belts and
suspenders . . . . That's why I put the emphasis on some kind of balance here
with the LSAT and the college score. Those are the two biggest things . . . .
[O]ur feeling is that especially in this middle zone where the LSAT and the
college record kind of balance one another, they reinforce one another, it's a
little more reassuring, and reassurance is what you are looking for. You're
not going to get excited about these margin candidates.
Wellborn, vol. 1 at 87-88.
Part of the plaintiffs' strategy throughout the remand trial has been to find
the files of a small handful of 1992 admittees who the law school faculty
members opined were as qualified, or in a few instances, perhaps less qualified
for admission than the plaintiffs.[51] This
evidence does not persuade the Court to disregard the conclusions Wellborn
reached in his expert report or the assessments made by faculty members who
originally reviewed the plaintiffs' files in 1992. The fact that a small
number of admittees[52] had credentials
similar to or worse than the plaintiffs does not lead one to the conclusion
that the plaintiffs would have been admitted in a race-neutral process. At
most, this evidence proves that the plaintiffs had some chance of admission,
however slim, a proposition the law school has conceded all along.[53] See Wellborn, vol. 1 at 115. But
having "some" chance of admission does not correlate to having a reasonable
chance, which is the inquiry required by the burden of proof in this case.
Moreover, the plaintiffs' argument rests on a fallacious premise. The
plaintiffs have identified the lowest common denominator and, after determining
that the plaintiffs meet or exceed that standard, have concluded that the
plaintiffs would therefore have a reasonable chance of admission (or,
conversely, that the defendants cannot prove that the plaintiffs do not have a
reasonable chance of admission). The comparison to be drawn, however, is not
among individual applicants but among the entire applicant pool. It simply
does not follow that anyone on a par with the least qualified admittee would
have a reasonable chance of admission, and it certainly does not reflect the
way in which the law school selects its entering classes. Frankly, the Court
draws quite the opposite inference--the fact that so few applicants comparable
to the plaintiffs were actually admitted in 1992 is evidence that the
plaintiffs probably would not have been offered admission in a constitutional
process.
Finally, each of the plaintiffs has one or more significant weaknesses in his
or her application that are not counterbalanced by a specific strength.
Hopwood earned 70 of her undergraduate hours at community colleges. See
Johanson Declaration D-332 (indicating that community colleges tend to be
"non-competitive institutions with academically weak student bodies and
faculties"); Declaration of Elizabeth Chambliss, D-338 (indicating that
less than 1% of resident nonminorities admitted in 1992 had more than 70 hours
of undergraduate education at a community college or junior college). Hopwood
required 6 years to complete her associate's degree, resulting in an average of
10 credit hours per year. See P-145 (LSDAS record); 1994 trial
transcript, Johanson, vol. 5 at 15 (stating that Hopwood earned her
GPA on "a fairly slow track"). She subsequently obtained a bachelor's degree
from a university that is uncompetitive with the universities attended by the
vast majority of students who are admitted to the law school. See Chambliss
Declaration, D-338 (indicating that less than 2% of resident nonminorities
admitted in 1992 graduated from schools with college LSAT mean scores of 28 or
below).
Wellborn testified that Hopwood's LSAT score was acceptable for a marginal
candidate. See Wellborn, vol. 1 at 67. Likewise, Hopwood's
non-academic strengths (her age, the fact that she was the mother of a
handicapped child, had worked her way through college, and later became a CPA)
merit some "preferential consideration." See Sharlot Declaration
D-334. However, according to Wellborn and the admissions committee members who
reviewed Hopwood's application in 1992, these positive attributes ultimately do
not outweigh the negative aspects of her application, the most important factor
of which is the weakness of her undergraduate education. See Wellborn,
vol. 1 at 67-68; Johanson Declaration D-332 ("Her transcript shows not
only that she attended weak schools, but that the bulk of her education was in
technical 'how-to' courses rather than academic courses requiring analytic
skills. . . . Hopwood is simply not well-prepared academically for Law
School."); Hamilton Declaration D-333 (stating that Hopwood's
undergraduate record "reflects little analytic preparation for law school");
Sharlot Declaration (concluding that Hopwood's file "is very weak in
comparison with the overwhelming credentials of so many of our applicants").[54]
As the Court noted in Hopwood I, there is little else to Hopwood's
file. She provided no letters of recommendation, no personal statement, and
the handwritten application is among the least impressive in appearance of all
of the files examined by the Court.[55]
See Hopwood I, 861 F. Supp. at 581; Johanson Declaration D-332
("It is also striking to see no letters of recommendation, particularly for an
older applicant who has been out of school a while."). Wellborn summed up her
application as follows:
So the overall picture here I think is one that would raise a lot of concern
because we don't have a candidate who has been tested at a highly competitive
college environment as many, many of our applicants have. A lot of it is kind
of like high school, frankly, community college, and so forth, and we--of
course, we all know from our own personal experience of the high school honor
student who goes to the major state university and doesn't fair [sic]
very well. It's a lot tougher. And, of course, we feel that the University of
Texas Law School is a lot tougher still. So that would be a concern here.
Wellborn, vol. 1 at 68.
Carvell's "true" TI score of 191 or 192 placed him with the group of
applicants who were presumptively denied admission in 1992. Only approximately
5% of candidates with TI scores of 191 and 15% of candidates with TI scores of
192 were admitted to the law school in 1992; therefore, it is not surprising
that Carvell was denied admission, as he was among an overwhelming majority of
applicants with the same TI score who were not admitted. Although Carvell's
personal statement was "well-written," see Wellborn, vol. 1 at
127, Wellborn testified that it did not compensate for the overall weakness of
his application. Both Carvell's GPA of 3.28 and LSAT score in the 76th
percentile were significantly below the 1992 overall GPA median of 3.52 and
overall LSAT median in the 89th percentile. See Hopwood I, 861 F. Supp.
at 563 n.32; Hopwood II, 78 F.3d at 937 n.7; see also Sharlot
Declaration D-334 ("The most striking feature [of his file] is his
undergraduate GPA at a school with an extremely low mean LSAT score . . . . I
am also struck by the fact that this relatively unimpressive performance was by
a graduate of what is reputedly one of the best public high schools in the
state [Highland Park High School in Dallas, Texas]."); Gergen
Declaration D-335 (characterizing Carvell as "an easy no vote" and
indicating that his GPA was weak "even at a school that I don't suspect is very
demanding"); Goode Declaration D-336 ("Mr. Carvell's transcript reveals
a mediocre academic record from a mediocre school . . . . If Mr. Carvell could
not finish in the top two-fifths of his college class, what chance is there
that he would perform well in a much more competitive environment?").
Carvell provided two faculty and two professional letters of recommendation,
which one of his 1992 faculty reviewers described as "strikingly weak." See
Goode Declaration D-336. At the remand trial, Wellborn described one of
the faculty letters as "not very strong" and "vague." See
Wellborn, vol. 1 at 74. The other faculty letter by all accounts is
downright negative, characterizing Carvell's classroom performance as
disappointing, mediocre, and uneven. See P-151; Gergen
Declaration D-335 ("I also cannot help but be impressed by a rare honest
letter of recommendation intimating that Mr. Carvell is either lazy or
unfocused."); Goode Declaration D-336 ("It is a letter that first damns
with faint praise and then damns without faint praise. In this day of inflated
grades and recommendations, I would definitely take notice of such a tepid
assessment of Mr. Carvell's performance as an undergraduate."). In addition,
Carvell was denied admission to Vanderbilt Law School, a school which was
generally considered inferior to the University of Texas in terms of national
reputation. Carvell was also denied admission to the University of Texas
Graduate School of Business, which is less competitive than the law school in
terms of admissions, as well as Vanderbilt Business School. See Johanson
Declaration D-332; Carvell, vol. 4 at 112.
Elliot's weakness, according to Wellborn, was his lack of "belts and
suspenders," that is, his "consistently weak undergraduate record." See
Wellborn, vol. 1 at 82; Johanson Declaration D-332 ("[I]t is
preposterous to suggest that the . . . challenged affirmative action program
was the cause of his [denial] . . . . Elliot is simply a weak candidate.").
Wellborn testified that this type of "disparity" candidate--an applicant with a
high LSAT score and low GPA, or vice versa--is occasionally admitted, but only
when the scores are high enough to place the individual in the presumptive
admit zone. See Wellborn, vol. 1 at 88. Under those
circumstances, Wellborn testified, "there is a reason to take risks on [such]
candidates." Wellborn, vol. 1 at 88. Elliot did not provide any
faculty letters of recommendation,[56] leaving
the committee members with no information about his college record except his
"rather unimpressive 40th percentile class rank." See Wellborn, vol. 1
at 81-82. Even Elliot himself acknowledged his weak college record in his
personal statement: "I was an average student, studying when I needed to,
partying more than I should, and not managing my time efficiently. . . . [My
GPA] is not of a caliber expected by the University of Texas School of Law."
P-153. Furthermore, Elliot was denied admission to Baylor Law School, a school
which is less competitive in terms of admission standards and, importantly, one
that did not operate a significant affirmative action program in 1992. See
Johanson Declaration D-332.
One of the issues the Court decided in the first trial was whether Elliot had
standing to sue the law school. Following Elliot's rejection by the law school
in April 1992, Elliot's father sent a letter to Dean Yudof complaining that the
law school had rejected his son's application because of the law school's
"mandatory minority and women quotas."[57]
See P-165 (copy of the letter sent by Elliot's father). It is
undisputed that Elliot's application was thereafter placed under
reconsideration. Hamilton testified that the law school offered Elliot
admission in August 1992, shortly before classes were to begin. The law school
asserted at the first trial that Elliot lacked the standing to sue because he
declined his offer of admission. See Hopwood I, 861 F. Supp. at 565-66.
On remand, the Fifth Circuit instructed the Court to reconsider its
"contradictory" findings in Hopwood I that (1) Elliot was not notified
of his admission to the law school, and (2) Elliot would not have received an
offer of admission even under a constitutional system. See Hopwood II,
78 F.3d at 957 n.57.
As the Court indicated in Hopwood I, Hamilton was the only law school
official to testify that Elliot was extended an offer of admission. Unlike
other applicants who were admitted late in the process, there was no
documentation in Elliot's file to substantiate Hamilton's claims, and Elliot
testified at the first trial that he was unaware he had been offered either a
place on the waiting list or admission to the law school. See Hopwood
I, 861 F. Supp. at 565-66. Indeed, Johanson testified at the first trial
that "it was 'quite unusual' for someone to be reconsidered and placed on the
waiting list without [his] awareness of the decision." See id. at 566
& n.44; 1994 trial transcript, Johanson, vol. 5 at 19.
Furthermore, the Court found several discrepancies in Hamilton's trial
testimony and affidavit, which, in addition to the troubling lack of
documentation, "weigh[ed] in Elliot's favor" in terms of determining whether
Elliot had standing to sue the law school. See id. at 566. The Court
therefore found in Hopwood I that no offer of admission had been
communicated to Elliot, that is, that no offer of admission had been
made.[58] Moreover, Elliot's application
was only placed under reconsideration because of the letter sent by Elliot's
father. In a race-neutral world, the letter would not have received the
special treatment that it did in 1992, and Elliot's application would not have
been reconsidered. See Wellborn, vol. 1 at 80-81.
Wellborn testified that Rogers's extremely weak college record prevented his
admission to the law school despite his relatively high LSAT score. Rogers
earned a bachelor's degree in professional writing, a non-standard major, from
the University of Houston-Downtown, a college with one of the lowest LSAT means
Wellborn testified he has ever seen.[59]
See Wellborn, vol. 1 at 83. Rogers's cumulative GPA of 3.13 was
significantly below the overall 1992 GPA median of 3.52. Although Rogers also
received a master's degree in professional writing from the University of
Southern California in 1992, one of the law school admissions committee members
who reviewed his file in 1992 described Rogers's performance there as
"decidedly unimpressive." See Gergen Declaration D-335. Prior to
graduating from the University of Houston-Downtown, Rogers attended the
University of Texas, where he was placed on scholastic probation once and
flunked out twice over a period of three and a half years.[60] Wellborn concluded that Rogers was "clearly" the weakest
of all of the applicants with a TI score of 197. Wellborn, vol. 1 at
82. And, Rogers's assertions that he was a "turnaround" candidate to the
contrary, Wellborn testified:
[T]his was not the picture of someone who just had a shaky start or one bad
semester when they were having trouble, but this was extended over a three and
a half year period. Three strikes. And that was his experience at a major
institution. . . . [H]e did make high grades later on at his degree school,
but it's not as through he transferred to a school that would provide a
rigorous testing ground in our opinion.
Wellborn, vol. 1 at 84. In addition, Rogers provided no letters of
recommendation and his answers to the questions on the application form were
brief and relatively uninformative. See P-171. Given Rogers's
disastrous three and a half years as an undergraduate at the University of
Texas and his subsequent failure to distinguish himself academically, the Court
is convinced beyond any doubt that Rogers would never be admitted to the law
school under any circumstances.
The Court regrets having to discuss publicly and in such great detail the
specific weaknesses in each of the plaintiffs' applications. It goes without
saying that their applications do not reflect the sum of their existence as
students or individuals. And even though the Court finds the plaintiffs were
not denied admission to the law school as a result of the unlawful use of
racial preferences, the Court once again acknowledges "the gravity of the
noneconomic injury to persons denied equal treatment." See Hopwood I,
861 F. Supp. at 583. On a final note, being denied admission to the University
of Texas School of Law should not be the defining moment in any of these
plaintiffs' lives. At the risk of sounding trite, there are much greater
tragedies in life. Each year the law school denies admission to many bright,
qualified, and deserving individuals simply because there are not enough spaces
available in each entering class. The plaintiffs should not let their denial
letters from 1992--or this lawsuit--continue to determine the course of their
lives or prevent them from becoming successful lawyers if that is a goal they
still wish to pursue.
IV.
The Court makes the following alternative findings of fact and conclusions of
law regarding each of the plaintiffs' damages to ensure there is no third trial
and for the benefit of the circuit court. It should be emphasized, however,
that the Court made the following finding in the first trial: "[H]ad the
plaintiffs been entitled to damages, none of them established monetary damages
as required under the law and rules of this circuit" because the evidence
presented merely "consisted of each plaintiff's testimony and speculation about
the value of a law degree." Hopwood I, 861 F. Supp. at 583. It is
beyond the intellectual skills of this Court to comprehend why the plaintiffs
have been given a second trial to present evidence regarding damages when they
utterly failed to present competent evidence on damages at the first trial.[61] Nevertheless, the Fifth Circuit has
instructed the Court to consider new evidence on damages, including damages
allegedly accrued since May 1994. See Hopwood II, 78 F.3d at 957
("[T]he law school's inability to establish the plaintiff's non-admission . . .
opens a panoply of potential relief, depending in part upon what course that
plaintiff's career has taken since trial in mid-1994.")[62]
Each of the plaintiffs, with varying degrees of enthusiasm, has requested on
order from this Court directing his or her admission to the law school.[63] See Hopwood, vol. 2 at 177;
Rogers, vol. 2 at 86; Elliot, vol. 3 at 268. To the extent the
Fifth Circuit concludes the plaintiffs were denied admission as a result of the
law school's unconstitutional admissions procedures, an injunction ordering the
law school to admit Hopwood, Elliot, and Rogers would be the most appropriate
and equitable remedy the Court could fashion. The remaining issues, therefore,
are (1) whether Hopwood, Elliot, and Rogers have proved any economic damages
for lost earnings in their second trial; (2) whether Carvell has established
any economic damages; and (3) whether Hopwood and Carvell have established any
damages for mental anguish.[64] The
plaintiffs must prove their damages by a preponderance of the evidence, and
damages which are too speculative, remote, or conjectural cannot be awarded.
Collectively, the plaintiffs request over five million dollars in compensatory
damages, three million dollars of which is sought for emotional injuries. This
figure is exponentially higher than the requests for damages made at the May
1994 trial. See 1994 trial transcript, T. Smith, vol. 26 at 40
(counsel for plaintiffs explaining to the Court in closing arguments that the
plaintiffs' damages "are not great").[65]
Hopwood, Elliot, and Rogers request damages for loss of future income
resulting from the delay in their legal education. The defendants contend
these so-called "front pay" damages are not available in nonemployment cases,
in part because they are not foreseeable by educational institutions.[66] They argue that the law school, in
rejecting thousands of applicants each year, does not foresee that denied
applicants will forego their law school plans entirely but merely that they
will have to attend law school elsewhere. While the foreseeability of a
plaintiff's injury is irrelevant in the context of intentional torts,[67] the argument raises two related points. The
first point relates to the remote and speculative nature of the plaintiffs'
injuries. The Court emphatically rejects the notion that the defendants'
actions prevented Hopwood, Elliot, and Rogers from becoming lawyers. At most,
the law school prevented the plaintiffs from obtaining a law degree from the
University of Texas. Many rejected applicants--Carvell, for
instance--successfully attend other law schools. The second point pertains to
a plaintiff's ability to prove front pay damages in a Title VI case. As a
practical matter, front pay damages may simply be too speculative or attenuated
given the injury in this case--the denial of a seat in law school. Hopwood,
Elliot, and Rogers have the burden of establishing they would have successfully
graduated from the University of Texas and attained full-time employment as
lawyers. To the extent this case is remanded for damages, the Fifth Circuit
implicitly rejected the argument that front pay damages are always improper
under Title VI or too speculative as a matter of law. But in determining
whether a front pay award is appropriate in this case, the Court must grapple
with the inherently speculative nature of the plaintiffs' damages--
particularly when, as in the case of Hopwood and Carvell, the requests for
damages extend forty years into the future. With these two thoughts in mind,
the Court now turns to each plaintiff's request for damages.
A.
Hopwood contends she suffered economic damages in the amount of $1,360,000,
which she claims is the projected career earnings differential between an
accountant, her current profession, and an attorney. See P-477.
Hopwood additionally seeks $1,500,000 in emotional distress damages she claims
resulted from her denial of admission to the law school. See P-459.
(1) Damages for Loss of Future Income
Hopwood is not entitled to any monetary damages for the alleged loss of future
income as an attorney. The Court fails to find from a preponderance of the
evidence that Hopwood would have completed her law degree by January 1996: she
would not have graduated from law school due to a series of personal tragedies
occurring from 1992 to 1996, the time period during which she would have been
attending law school. Hopwood contemplated limited enrollment at the law
school before she applied for admission in 1992. In a letter attached to her
application to the law school, Hopwood sought information regarding reduced
participation so that she could continue to care for her severely handicapped
daughter Tara while attending law school. See Hopwood, vol. 1 at
132-33. Hopwood testified at trial that Tara "required a substantial amount of
energy and time, and had a large number of doctors appointments and hospital
visits [and] surgeries." See Hopwood, vol. 2 at 239. Furthermore,
Hopwood's husband was in the military and traveled extensively, see
Hopwood, vol. 2 at 239, during which time Hopwood was Tara's primary
caretaker. In addition, Hopwood was living in San Antonio, Texas at the time
and would have been commuting to the law school seventy miles each way for
three years.
Hopwood became pregnant with her second daughter Erica in August 1992,
immediately before the start of the law school Fall semester. See
Hopwood, vol. 2 at 221. During what would have been the end of Hopwood's
first year in law school, Erica was born. Erica passed away on May 18, 1993,
the day following her birth. See Hopwood, vol. 2 at 221. Hopwood
continued as Tara's primary caretaker and began experiencing marital
difficulties due to the stress and depression related to the impending death of
Tara and to the demands Hopwood placed on her husband to move away from Texas.
See Hopwood, vol. 2 at 170-71, 222-23. In June 1995, Hopwood and her
husband separated, presumably leaving Hopwood as Tara's sole caretaker. On
November 23, 1995, Tara passed away. Hopwood, vol. 2 at 176. In
February 1996, Hopwood relocated from San Antonio, Texas to Columbia, Maryland,
and her husband moved to Korea. See Hopwood, vol. 2 at 222-23.
Hopwood's limited employment during this time reflects the toll these events
took on her professional life. Hopwood was unemployed from June 1991 to
January 1993. See Hopwood, vol. 2 at 229. From January 1993 to May
1995, Hopwood worked on a part-time basis as a CPA for a sole proprietorship in
San Antonio; although she worked full-time during tax season, she was able to
do so only because she frequently worked out of her home. See Hopwood,
vol. 2 at 230-31, 240. In anticipation of her move to Maryland, Hopwood was
not employed from May 1995 to February 1996. See Hopwood, vol. 2 at
232. From February 1996 to May 1996, Hopwood worked as an accountant for a
temporary agency, and for most of the remainder of the year she was unemployed.
In January 1997, Hopwood received her first full-time employment as a CPA since
mid-1991. See Hopwood, vol. 2 at 228, 233-34. Hopwood testified that
she could have worked full time as a CPA during these years, but she choose not
to do so in part because she knew she had a limited amount of time with her
daughter Tara. See Hopwood, vol. 2 at 240.
The Court is not suggesting that women with families or severely handicapped
children are incapable of successfully pursuing a law degree or that
individuals who suffer tremendous personal tragedies lack the will or ability
to accomplish their goals. However, in this case the facts are clear: Hopwood
was facing many serious obstacles, as well as enormous time constraints, that
would have undermined her ability to earn a law degree during the 1992 to 1996
time frame. It would have been virtually impossible for anyone--female or
male--to complete a law degree traveling 150 miles per school day to a highly
competitive environment such as the University of Texas while undergoing
similar strains in his or her personal life.[68] Supporting the Court's finding that Hopwood would not
have graduated from law school is her own testimony. See
Hopwood, vol. 2 at 172 (testifying that "Tara died unexpectedly . . . I
didn't feel I was mentally or emotionally ready to handle what I know is a very
difficult coarse [sic] load in the law program"); Hopwood, vol. 2
at 175-76 (testifying that she has had a "sporadic work history" since Tara's
death). Hopwood's previous academic performance supports the Court's
conclusion as well. It took Hopwood eight years (instead of four) to earn her
undergraduate degree because difficult financial circumstances forced her to
spend much of her time working. In addition, although Hopwood repeatedly
refers to earning a law degree as a lifelong dream, she has not demonstrated
her commitment to that goal by seeking admission to any law school following
her rejection from the University of Texas in 1992. See Hopwood, vol. 2
at 172.
Even assuming Hopwood would have completed her law degree, the evidence she
proffered to prove economic damages did not reasonably predict any loss in
earnings she may have suffered as a result of her denial of admission to the
law school. Hopwood's first expert witness regarding her economic damages was
economist Wayne E. Ruhter, Ph.D. Ruhter performed two analyses, "Analysis I"
and "Analysis III," to determine the career earnings differential between
attorneys and accountants. See P-477. In Analysis I, Ruhter compared
attorney salaries in the private sector in Texas and the mid-Atlantic region
with accountant salaries in Philadelphia.[69]
See P-477, Exhibit I, Tab 3, Analysis 1-Table 3. Ruhter assumes Hopwood
would progress from associate to partnership level in both career paths. In
Analysis III, he utilized 1990 Census data, which did not reflect any
particular career path or geographic location, to determine the difference in
career earnings between female attorneys and female accountants. See
P-477, Exhibit III, Tab 3, Analysis 3-Table 3. In both Analysis I and III,
Ruhter assumed Hopwood would have graduated from law school, passed the bar
exam, attained full-time employment by January 1996, and continued working
until she reached age 75 in the year 2037. Subtracting the costs of attending
law school, Ruhter concluded the present value of Hopwood's economic damages to
be $424,604 in Analysis I and between $400,364 and $416,876 in Analysis III.
See Ruhter, vol. 2 at 258, 265-66. Finally, Ruhter concluded in
Analysis II that Hopwood could not have mitigated her damages by enrolling in
law school in 1997.[70] See Ruhter,
vol. 2 at 272.
In the Court's opinion, Ruhter's expert report was riddled with so many
untenable premises, logical inconsistencies, and unreliable and inappropriate
sources that it cannot support an award of economic damages. By Ruhter's own
admission, his expert report is merely "an evaluation of two career paths" that
examines the potential career earnings that are "available" to Hopwood as an
attorney and an accountant. Ruhter, vol. 2 at 253, vol. 3 at 48, 53.
Ruhter unequivocally stated that he did not specifically attempt to "forecast"
Hopwood's losses. Ruhter, vol. 3 at 71. Furthermore, prior to
preparing his expert report, Ruhter did not interview Hopwood or her current
employer or obtain enough information about Hopwood to predict her future
earnings capacity to any reasonable degree of certainty. See Ruhter,
vol. 3 at 45, 48-49. It is from this initial, misguided premise that all other
errors in his report flow. Some, but by no means all, of the more glaring
problems are described below.
First consider Analysis I. The accountant career path does not reasonably
predict Hopwood's future earnings. Ruhter uses salary information from
Philadelphia to predict future earnings (even for 1997) instead of reasonably
predicting earnings from her current employment in Columbia, Maryland.
See Ruhter, vol. 3 at 53. Similarly, the attorney career path is
implausibly optimistic, resulting in wildly inflated future earnings. Ruhter
assumes Hopwood would (1) become a partner (2) in eight years (3) in a private
law firm (4) in a large city in Texas or the mid-Atlantic region. That
particular career path is one of the most lucrative a lawyer can take and is
extremely difficult and rare. See D-513, Report of Stephen Mims;
Ruhter, vol. 3 at 48-49 (recognizing that salaries for private law firm
practice are generally higher than for government, corporate, or public
interest practice); Mims, vol. 3 at 236 (stating that approximately less
than 9% of University of Texas law graduates from the class of 1987 are
partners at large law firms by the year 1996). Furthermore, because empirical
information related to partnership buy-ins was unavailable, those costs are not
reflected in Analysis I.[71] See
Ruhter, vol. 2 at 268-69. The Court also questions the use of the David J.
White Survey as an appropriate source to project the growth rate of attorney
salaries. See D-684, Tab 17 (indicating the survey does not ensure that
the same law firms respond to the survey each year it is given).
The most compelling reason to discount Analysis I, however, is its logical
inconsistency. Hopwood graduated with an accounting degree in 1988 and earned
her CPA license in 1991. See Hopwood, vol. 2 at 140-41. Ruhter does
not begin to measure Hopwood's earnings capacity as an accountant, however,
until 1997. Prior to 1997, Ruhter uses Hopwood's actual earnings, which, due
to her personal circumstances, were low. See P-483. Had Ruhter
properly measured Hopwood's earnings capacity as a CPA starting in 1992, his
own methodology reflects that she would have earned more money over her
lifetime by continuing to work as an accountant as opposed to enrolling in law
school in 1992. See D-508, Report of James R. Vinson, Ph.D., Table I
(indicating that Hopwood's career earnings as a CPA would have exceeded her
attorney career earnings by $31,412); see also Ruhter, vol. 2 at 271
(acknowledging that there is an opportunity cost associated with a delay in
education). If, as Ruhter testified, Analysis I was intended to be a
hypothetical comparison of the lifetime earnings available to Hopwood as an
accountant and as a lawyer, the analysis should have accounted for Hopwood's
ability to earn as an accountant since the time she earned her degree in 1988
or, at the very latest, since she obtained her CPA license in 1991.
The chief problem with Analysis III is the unreliability and inappropriateness
of the Census data which serves as the source for Ruhter's conclusions. The
salary information reflected in the data is self-reported by employees.
Self-reporting does not, in and of itself, necessarily render the data
inaccurate, but in this case there are other indicia of unreliability. First,
some of the data is implausible on its face. For instance, the Census includes
salary information on individuals with less than a high school education who
claim to be lawyers. See P-477, Exhibit III, Tab 11. Second, the
Census significantly undervalues Hopwood's future earnings potential as an
accountant because the data pertaining to accountant salaries includes
information for bookkeepers and accountants who, unlike Hopwood, have not
obtained a CPA license. See Ruhter, vol 3 at 44-45, 94-95. Unrelated
to the problem of self-reporting is the fact that salary information is
categorized by age and, consequently, years of experience. While the average
age of a female law graduate is twenty-six, Hopwood would have been thirty-four
had she graduated from the law school in 1995. See Ruhter, vol. 2 at
266. Ruhter overstates Hopwood's earnings potential as a lawyer because the
Census data he uses in Analysis III compares Hopwood to females who, as a
result of their additional eight years of experience, would undoubtedly have
higher earnings than Hopwood. See P-477, Exhibit III, Tab 11. Ruhter
belatedly recognized this problem and performed Alternative Analysis III, in
which he replaces the Census data related to lawyer salaries for the years 1995
to 2000 with data from the David J. White Survey. This approach is perhaps
even more flawed because it improperly compares two sources of data for
attorney salaries (five years of data from the David J. White Survey and
thirty-five years of data from the Census) and only one source of data for
accountant salaries (forty years of data from the Census). As Ruhter himself
acknowledged, as a general rule it is inappropriate to use different sources of
information in a comparative study because doing so can create a bias in the
results. See Ruhter, vol. 3 at 56.
The remaining $900,000 Hopwood claims in economic damages is based on the
testimony of Bradford W. Hildebrandt. Hildebrandt is chairman of Hildebrandt,
Inc., a management consultant and placement firm related to the legal
profession. See D-501 (Hildebrandt's Report). Hildebrandt is not an
economist and did not perform an independent study of Hopwood's economic
losses. See Hildebrandt, vol. 3 at 106. Instead, he reviewed the
accuracy of the attorney compensation figures in the private sector as
reflected in Ruhter's Analysis I. Hildebrandt testified that Ruhter's figures,
which project an average annual partner salary of $219,699, undervalue
partnership compensation for University of Texas graduates by approximately
$100,000 per year. See Hildebrandt, vol. 3 at 107. The Court
rejects Hildebrandt's testimony for two reasons. First, Hildebrandt's
testimony was wholly dependent upon the accuracy of Ruhter's Analysis I, which
the Court has already found unpersuasive. Second, his testimony was inapposite
to Hopwood's case. It is sheer speculation whether Hopwood would have
completed law school, much less whether she would have had an academic record
sufficient to result in her recruitment by a private law firm, whether she
would have remained at that law firm for eight years, and whether she would
have been selected as a partner in that law firm. In short, Hopwood has failed
to establish by a preponderance of the evidence that she has suffered the
economic damages alleged as a result of being denied admission to the law
school.
(2) Mental Anguish Damages
Neither the Supreme Court nor the Fifth Circuit has specifically held that
mental anguish damages are recoverable in a suit brought pursuant to Title VI.
Although a majority of the Supreme Court in Guardians Association v. Civil
Service Commission of City of New York, 463 U.S. 582, 103 S. Ct. 3221
(1983), would allow a plaintiff to recover compensatory damages for intentional
violations of Title VI, the Supreme Court did not definitively describe the
scope of such remedies under the statute. See Shinault v. American
Airlines, Inc., 936 F.2d 796, 803 (5th Cir. 1991) (quoting Guardians
for the proposition that damage remedies under Spending Clause statutes such as
Title VI may be limited). The lower federal courts have been grappling with
the issue since Guardians, and the law in this area is therefore
somewhat muddled. See, e.g, Eastman v. Virginia Polytechnic
Inst., 939 F.2d 204, 208 (4th Cir. 1991) (concluding that compensatory
damages for pain and suffering are not available under Title VI and Section 504
of the Rehabilitation Act of 1973, as amended, 29 U.S.C. § 794 (West
1994), which forbids discrimination on the basis of disability).
In Franklin v. Gwinnett County Public Schools, 503 U.S. 60, 71, 112 S.
Ct. 1028, 1035 (1992), the Supreme Court held that "federal courts have the
power to award any appropriate relief" under Title IX, a statute that was
patterned after Title VI.[72] Since
Franklin, the strong trend among federal courts is to allow plaintiffs
to recover for mental injuries under Title VI and similar federal
anti-discrimination statutes. See Rodgers v. Magnet Cove Pub. Sch., 34
F.3d 642, 644 (8th Cir. 1994) (holding that "the full spectrum" of legal and
equitable remedies are available under Title VI and Section 504 of the
Rehabilitation Act of 1973); Waldorp v. Southern Co. Serv., Inc., 24
F.3d 152, 156-157 (11th Cir. 1994) (citing Franklin for the holding that
the full panoply of legal remedies are available under Section 504 of the
Rehabilitation Act); Pandazides v. Virginia Bd. of Educ., 13 F.3d 823,
830 (4th Cir. 1994) (overruling Eastman in light of Franklin).
In any event, this issue is a question of law that is better left to the Fifth
Circuit should the panel deem it proper to reach the issue of damages. The
Court merely assumes for purposes of this order that mental anguish damages are
recoverable under Title VI.
To the extent the Court fails to find by a preponderance of the evidence that
Hopwood would have completed her law degree, the defendants are not liable for
any mental anguish damages because there is no causal connection between the
harm and the violation. See, e.g., Patterson v. P.H.P
Healthcare Corp., 90 F.3d 927, 938 (5th Cir. 1996) (asserting the general
principle that there must a causal connection between the injury and any award
for damages). Even assuming Hopwood would have earned a degree from the law
school, several of Hopwood's claims for emotional injury are not compensable
because they are not the result of the defendants' conduct. For example,
claims for damages related to Hopwood's allegation that the defendants falsely
maligned her qualifications in the media pertain to the litigation she
initiated and the justifiable defense of this case and therefore are not
recoverable.[73] See Hopwood, vol. 2
at 187-90 (describing her voluntary media appearances and interviews). Other
claims for damages, such as her contention that the law school's discrimination
was a factor that caused her to begin smoking, are frivolous and do not merit
discussion.
Hopwood testified she experienced frustration, depression, disappointment,
diminished self-confidence, and anger as a result of being denied admission to
the law school. See Hopwood, vol. 2 at 170. In her interrogatory
responses, Hopwood also claims feelings of hopelessness, confusion, anxiety,
embarrassment, inability to concentrate, indecisiveness, inadequacy, and
stigmatization. See P-459; P-464. Finally, she contends her rejection
by the law school indirectly strained her marriage. See Hopwood, vol. 2
at 170-71; P-470 (deposition testimony of friend confirming these feelings).
Hopwood testified she did not experience any physical symptoms or pain, nor did
she seek any psychiatric or medical care, as a result of being denied
admission, although she did occasionally discuss the situation with a therapist
from whom she had sought grief counseling following Erica's death. See
Hopwood, vol. 2 at 217-18.
In addition to Hopwood's testimony, the Court heard corroborating evidence
regarding the nature and extent of her emotional injuries from Paul Lees-Haley,
Ph.D. Lees-Haley is a forensic psychologist, not a mental health provider, and
has never treated Hopwood for any mental injury. Rather, Lees-Haley evaluated
Hopwood based upon her self-reported complaints to determine whether Hopwood
suffered any emotional injury as a result of the defendants' actions.
See P-526 (Expert Report); Lees-Haley, vol. 3 at 153. Lees-Haley
testified that Hopwood suffered some emotional distress from three independent
sources: (1) the law school's discrimination against her, (2) the law school's
rejection of her application for admission, and (3) public comments made by the
law school and her interactions with lawyers in the case. See
Lees-Haley, vol. 3 at 152.
Lees-Haley diagnosed Hopwood with chronic "adjustment disorder with mixed
anxiety and depressed mood," which he believes occurred partly in response to
the "stressor"[74] of being denied admission
and of being a victim of discrimination. See Lees-Haley, vol. 3 at
155-56. He states in his report that adjustment disorder "typically resolves
within six months unless the symptoms are in response to . . . a stressor that
has enduring consequences," such as Hopwood's rejection from the law school.
P-526. Lees-Haley also testified that the law school's actions aggravated
other mental injuries, such as those resulting from the deaths of her children,
the break-up of her marriage, and the loss of a job. See Lees-Haley,
vol. 3 at 152; P-526 ("[Hopwood] plausibly suggests that had she been accepted
to law school, some of the other problems and their effects might have been
mitigated to some degree . . . because at least she would not have had the
feeling she had lost all of her dreams at once."). On the other hand,
Lees-Haley testified that the law school's actions "might have caused some mild
disability in the sense of making it harder for her to concentrate," but that
they have not caused Hopwood any "permanent" problems that will cause her "pain
and suffering and disability . . . for the rest of her life."
Lees-Haley, vol. 3 at 154; vol. 3 at 209-11 (indicating that Hopwood is
not suffering from any disability and is fully functional). Moreover, he
opined that Hopwood would not have had a diagnosable mental condition were it
not for other negative "stressors" in her life. See Lees-Haley, vol. 3
at 220-21.
Hopwood has had more than her share of tragedies, both before and after she
was denied admission to the law school, all of which have caused her severe
emotional distress. Without doubt, the evidence establishes the least
traumatic "stressor" in her life was the law school's denial of her
application. However, because of the unusual circumstances occurring in
Hopwood's personal life from 1992 through 1996 and her mental condition, the
Court would find from a preponderance of the evidence that Hopwood has suffered
mental anguish damages as a result of the law school's rejection of her
application. The denial of admission aggravated Hopwood's preexisting
emotional injuries beyond the mere hurt feelings, frustration, and anger that
are a part of everyday life. See Patterson, 90 F.3d at 940.
Accordingly, the Court would find from a preponderance of the evidence that
Hopwood has sustained mental anguish damages in the amount of $6,000 as a
result of the law school's rejection of her application for admission.
B.
Carvell is the only plaintiff who pursued a law degree in 1992 after his
rejection from the law school. Carvell graduated with a joint degree in law
and a master's in business administration from Southern Methodist University
("SMU") in 1996. See Carvell, vol. 4 at 101. Since August 1996, he has
been employed as an attorney with the private law firm of Bickel & Brewer
in Dallas, Texas,[75] where he was earning a
starting salary of $50,000 plus benefits at the time of trial (Carvell has
since earned a pay increase). See Carvell, vol. 4 at 105-06, 114-15.
Carvell seeks total economic damages in the amount of $705,886, consisting of
$40,036 in increased tuition for attending SMU and $665,850 in damages
resulting from the diminished value of an SMU law degree.[76] See P-478. Additionally, Carvell seeks
$1,500,000 in mental anguish damages resulting from the law school's
discrimination against him and the denial of his application for admission.
See P-460.
(1) Tuition Differential
Carvell would have attended the University of Texas over SMU Law School had he
been admitted to the law school in 1992. See Carvell, vol. 4 at
98; 1994 trial transcript, Carvell, vol. 10 at 9. Accordingly,
the Court finds from a preponderance of the evidence the difference in the cost
of tuition between the two schools was $40,036. See P-478, Exhibit 2,
Table 2; Ruhter, vol. 3 at 4.
(2) Damages for Loss of Future Income
Ruhter calculated the diminished value of Carvell's degree by comparing the
difference in earnings hypothetically available to University of Texas and SMU
law graduates based upon the average starting associate salaries of all private
law firms that recruited at those two schools in 1995, regardless of whether
those firms actually hired graduates of those two law schools that year.
See Ruhter, vol. 3 at 3; P-478, Exhibit 3, Table 3. Ruhter did not
identify any salary differential at the partnership level because he was
unaware of any empirical information available to calculate it; therefore,
Ruhter analyzed Carvell's alleged lost earnings only as an associate until the
year 2003. See Ruhter, vol. 3 at 80-81; P-478, Exhibit 3, Table 3.
Ruhter testified that the present value of the earnings differential was
$11,850. Ruhter, vol. 3 at 4. Hildebrandt reviewed the accuracy of the
figures contained in Ruhter's report. He testified that Ruhter underestimated
Carvell's losses by not carefully analyzing "the weight of the law schools" and
by not including any damages for the differential in partnership compensation
between graduates of SMU and the law school. Hildebrandt testified these
damages were approximately $50,000 per year, for a total of $654,000.
Hildebrandt, vol. 3 at 110-11.
The Court fails to find from a preponderance of the evidence that Carvell is
entitled to any damages for loss of future income; indeed, his requests for
economic damages are counterfactual. First, Carvell did not use the Career
Services Office at SMU to obtain any employment. See Carvell, vol. 4 at
122. Consequently, a comparative analysis of the average starting salaries of
law firms that recruit at the University of Texas and SMU provides an
inappropriate basis for measuring damages in Carvell's case. Second, Ruhter
calculates Carvell's lost earnings beginning in mid-1995 even though Carvell
did not graduate from law school until May 1996. See Carvell, vol. 2 at
122. Third, the "opportunity" differential between SMU and the University of
Texas is due in large part to the high starting salaries of national firms and
regional boutiques which tend to recruit more heavily at the University of
Texas. In general, these firms only hire top-tier students with very strong
academic records. See Jones, vol. 4 at 82-84. Carvell, however,
graduated in the third quarter of his class at SMU; therefore, these higher
earnings probably would not have been available to Carvell because he would not
have had an academic record at the University of Texas sufficient to result in
recruitment by those firms. See Carvell, vol. 4 at 114. Fourth, in
requesting $654,000 for the differential in partnership compensation,
Carvell apparently overlooked the salient fact that he is not on partnership
track at Bickel & Brewer.[77] See
Carvell, vol. 4 at 106.
Carvell proffered speculative evidence that he has suffered lost earnings as a
result of not obtaining his degree from the law school. In fact, the evidence
suggests Carvell has suffered no loss in earnings: Carvell's starting salary is
higher than the average starting salary for graduates of the University of
Texas in 1995. See D-685, Tab 4 (indicating that the average starting
salary for 1995 University of Texas graduates was $49,761); D-685, Tab 8
(indicating that the average starting salary for 1995 SMU graduates was
$51,464). Even assuming an earnings differential exists and that it can be
quantified to a reasonable degree of certainty--a notion the Court seriously
doubts--the statistics regarding average starting salaries in private,
government, corporate, and public interest practice suggest the differential
actually favors SMU graduates. See D-685, Tab 4 & 8. Moreover,
Carvell proffered no evidence that private law firms distinguish among lawyers,
in terms of salary and/or benefits, on the basis of where they obtained their
law degree. True, graduates of highly regarded universities tend to have
enhanced career opportunities over graduates of universities that are not as
highly regarded. But, in the Court's opinion, the ability of an individual to
succeed in his or her profession depends much more upon the value of that
individual rather than the value of his or her degree.[78]
(3) Mental Anguish Damages
Carvell testified he experienced disappointment, anxiety, stress, shock,
frustration, and anger and that he became withdrawn from others as a result of
his denial of admission to the law school. See Carvell, vol. 4 at
98-101; P-472 (deposition testimony of friend confirming these feelings). In
his interrogatory responses, Carvell also indicated he suffered feelings of
confusion, depression, embarrassment, inability to concentrate, lack of
motivation, indecisiveness, diminished confidence, inadequacy, stigmatization,
and diminished self-esteem. See P-460; P-465. On the other hand, he
testified he was not "shattered or crippled" by the experience and that he is
functioning well at his current employment. See Carvell, vol. 4 at 101.
Moreover, Carvell never sought psychiatric or medical treatment for any
emotional injuries caused by the defendants' conduct, even though he has
suffered from "very serious and substantial mental health problems in the
past." Carvell, vol. 4 at 101, 119-20; Carvell Stipulation 1.
As with Hopwood, Lees-Haley evaluated Carvell's self-reported complaints to
determine the nature and extent of his emotional injuries resulting from the
defendants' actions. Lees-Haley stated in his expert report that "Carvell
appears to have a chronic, mild depression that pre-existed this injury and
continues to the present, which was temporarily mildly aggravated by not
being admitted to the University of Texas School of Law and by discovering that
he was the subject of race discrimination." See P-527 (emphasis added).
The Court does not find from a preponderance of the evidence that the denial of
admission caused Carvell any compensable emotional injuries, either by
themselves or resulting from the alleged temporary aggravation of his
preexisting depression. The denial, at most, resulted in the mere hurt
feelings, frustration, and anger that are simply a part of everyday life.
C.
Elliot seeks $56,021 in lost earnings he contends resulted from his delayed
entry into the workforce as a lawyer during the pendency of this lawsuit. He
arrived at this figure by calculating the five-year differential, adjusted for
inflation and discounted to present value, between his current salary as a CPA
and the average starting salary of 1995 graduates of the law school. The Court
does not find from a preponderance of the evidence that Elliot has suffered any
loss in earnings as an attorney that can be reasonably attributed to his
rejection by the law school. Elliot declined an offer of admission to attend
Texas Tech Law School in 1992. See Elliot, vol. 3 at 273.
Therefore, the delay in his legal education resulted not from the law school's
admissions procedures but from Elliot's deliberate choice not to attend Texas
Tech. Furthermore, separate from the issue of the remoteness of the injury is
the issue of whether Elliot has mitigated his damages. Elliot could have
attended Texas Tech in 1992 or he could have applied to other law schools
within the last five years. The damages Elliot seeks are also speculative and
remote.
D.
Rogers seeks compensatory damages of $332,867.94 plus one third of any amount
awarded in attorneys' fees.[79] See
D-660, Exhibit A. Rogers claims approximately $200,000 in lost wages as a
lawyer during the pendency of the lawsuit; roughly half the lost earnings he
claims are losses he sustained in unpaid loans he made to his business.[80] In addition, Rogers seeks $200 for the cost
of reapplying to the law school, $795 to attend a Princeton Review LSAT course,
$950 in costs to move back to Austin in the event the Court orders an
injunction, a minority scholarship in the amount of $20,000 plus tuition for
three years, and $909.24 in expenses for voluntarily attending a conference on
affirmative action in California. The Court does not find from a preponderance
of the evidence that Rogers has sustained any economic damages as a result of
his rejection by the law school. The reasons are essentially the same for
which the Court denied Elliot's request for damages--the damages alleged are
not attributable to the defendants' conduct and are speculative and remote.
Rogers declined an offer to attend the University of Houston School of Law in
1992. See Rogers, vol. 2 at 100. The remaining requests for damages
(those that do not relate to Rogers's request for lost earnings) are frivolous
and do not merit discussion.
V.
Title 42 of the United States Code, Section 1988, provides that a court "in
its discretion, may allow the prevailing party, other than the United States, a
reasonable attorney's fee as part of the costs." The Court denied the
plaintiffs' original requests for fees and expenses following the May 1994
trial, concluding that the plaintiffs, although prevailing parties under
statute, only attained de minimis relief. The plaintiffs separately appealed
that judgment on January 9, 1995. On July 26, 1996, the Fifth Circuit granted
the plaintiffs' motion to vacate the Court's judgment on attorneys' fees and
remanded the case with an instruction to reconsider whether the fees and
expenses requested at the trial and appellate levels were reasonable and
necessary for the prosecution of this case. The plaintiffs' attorneys
purportedly spent 7,241.41 hours litigating this case, and the fees and
expenses sought exceed $1.5 million.
At the May 1994 trial, the plaintiffs were represented by (1) Steven Smith;
(2) Terral Smith; (3) Joseph Wallace, Paul Harris, R. Kenneth Wheeler, and
Scott Wilson of the private law firm of Wallace, Harris & Sims ("WHS"),
located in West Virginia; and (4) Michael McDonald, Michael Rosman, Vincent
Mulloy, Michael Troy, and Joseph Shea of the Center for Individual Rights
("CIR"), a not-for-profit, public interest law firm located in Washington, D.C.
Steven Smith is an Austin sole practitioner who initiated the suit. He was the
only attorney representing the plaintiffs during the first eight months of the
case. Terral Smith, also a sole practitioner in Austin, conducted the majority
of the trial presentation. Along with Terral Smith (although to a lesser
degree), Wallace participated in the trial presentation, while the other
attorneys of WHS assisted in trial preparation. The CIR's main involvement in
the case was to conduct most of the legal research, write all legal briefs, and
bankroll the case. Following the 1994 trial, the plaintiffs sought fees and
expenses of $853,847.69 for 4,840.56 hours of work ("trial hours").[81] After the successful appeal of this case,
the plaintiffs increased their requests to $941,391.24 to reflect current
hourly billing rates.[82]
Beginning in November 1994, the plaintiffs (for reasons unknown to the Court)
obtained separate representation on appeal to the Fifth Circuit and the Supreme
Court. Hopwood and Carvell were represented by (1) Theodore Olson, Douglas
Cox, Thomas Hungar, Walter J. Scott, and Daniel Nelson of the Washington, D.C.
office of Gibson, Dunn & Crutcher ("GDC"); and (2) McDonald, Rosman, Troy,
and Hans Bader of CIR.[83] Terral Smith and
Steven Smith remained counsel of record for Elliot and Rogers. GDC primarily
handled the appeal relating to the constitutionality of the law school's use of
racial preferences, including briefing the issues to both appellate courts and
arguing the case to the Fifth Circuit. CIR worked on the appeals relating to
the proposed interventions by several minority groups and this Court's denial
of attorneys' fees. In addition, CIR had primary responsibility for
coordinating activity among the lawyers representing Hopwood and Carvell. It
appears Terral Smith and Steven Smith assisted GDC with the trial record
only--their billing records demonstrate they did little independent appellate
work and instead relied on GDC to argue the merits of the case to the Fifth
Circuit and the Supreme Court. The plaintiffs seek fees and expenses of
$614,138.56 for 2,400.85 hours of work during the appellate phase of this case
("appellate hours").[84]
A.
To determine the appropriate award, the Court must calculate the "lodestar" by
multiplying the number the number of hours reasonably spent on the litigation
by a reasonable hourly billing rate. See Hensley v. Eckerhart, 461 U.S.
424, 434, 103 S. Ct. 1933, 1939 (1983). The fee applicant bears the burden of
establishing that the hours expended and the billing rate are reasonable.
Id. at 437, 103 S. Ct. at 1941. The Court should consider the factors
set forth in Johnson v. Georgia Highway Express, Inc., 488 F.2d 714,
717-19 (5th Cir. 1974), to evaluate the reasonableness of the fee requests.
See Walker v. United States Dep't of Housing & Urban Dev., 99 F.3d
761, 771 (5th Cir. 1996) (indicating that most of the Johnson factors
are reflected in the lodestar amount and cannot be used to compute any upward
or downward adjustment of the lodestar); Watkins v. Fordice, 7 F.3d 453,
457 (5th Cir. 1993). The Johnson factors are (1) the time and labor
required; (2) the novelty and difficulty of the questions; (3) the skill
required to perform the legal services properly; (4) the preclusion of other
employment by the attorney due to acceptance of the case; (5) the customary
fee; (6) whether the fee is fixed or contingent; (7) time limitations imposed
by the client or the circumstances; (8) the amount involved and the results
obtained; (9) the experience, reputation, and ability of the attorneys; (10)
the "undesirability" of the case; (11) the nature and length of the
professional relationship with the client; and (12) awards in similar cases.
Watkins, 7 F.3d at 457 n. 4. As discussed below, the defendants challenge
the fees sought for certain categories of work performed by counsel, as well as
fees sought for duplicative, unnecessary, and excessive hours. Moreover, the
Court made certain discretionary reductions in accordance with the
Johnson factors.
(1) Public and Media Relations
The defendants argue the plaintiffs are not entitled to reimbursement for time
spent dealing with the media. As the defendants correctly contend, the Fifth
Circuit routinely denies such requests because they are not related to the
litigation of the case. See id. at 458; Associated Builders &
Contractors of La., Inc. v. Orleans Parish Sch. Bd., 919 F.2d 374, 380 (5th
Cir. 1990) (affirming the district court's decision to discount award for time
spent preparing press releases);