upheld the University of Michigan Law School's consideration of race and ethnicity in admissions. In her majority opinion, Justice O'Connor said that the law school used a "highly individualized, holistic review of each applicant's file." Race, she said, was not used in a "mechanical way." Therefore, the university's program was consistent with the requirement of "individualized consideration" set in 1978's Bakke case. "In order to cultivate a set of leaders with legitimacy in the eyes of the citizenry, it is necessary that the path to leadership be visibly open to talented and qualified individuals of every race and ethnicity," O'Connor said. However, the court ruled that the University of Michigan's undergraduate admissions system, which awarded 20 points to black, Hispanic, and American-Indian applicants, was "nonindividualized, mechanical," and thus unconstitutional.