Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al

Filing 419

DECLARATION re 417 MOTION for Summary Judgment by President and Fellows of Harvard College. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17, # 18 Exhibit 18, # 19 Exhibit 19, # 20 Exhibit 20, # 21 Exhibit 21, # 22 Exhibit 22, # 23 Exhibit 23, # 24 Exhibit 24, # 25 Exhibit 25, # 26 Exhibit 26, # 27 Exhibit 27, # 28 Exhibit 28, # 29 Exhibit 29, # 30 Exhibit 30, # 31 Exhibit 31, # 32 Exhibit 32, # 33 Exhibit 33, # 34 Exhibit 34, # 35 Exhibit 35, # 36 Exhibit 36, # 37 Exhibit 37, # 38 Exhibit 38, # 39 Exhibit 39, # 40 Exhibit 40, # 41 Exhibit 41, # 42 Exhibit 42, # 43 Exhibit 43, # 44 Exhibit 44, # 45 Exhibit 45, # 46 Exhibit 46, # 47 Exhibit 47, # 48 Exhibit 48, # 49 Exhibit 49, # 50 Exhibit 50, # 51 Exhibit 51, # 52 Exhibit 52, # 53 Exhibit 53, # 54 Exhibit 54, # 55 Exhibit 55, # 56 Exhibit 56, # 57 Exhibit 57, # 58 Exhibit 58, # 59 Exhibit 59, # 60 Exhibit 60, # 61 Exhibit 61, # 62 Exhibit 62, # 63 Exhibit 63, # 64 Exhibit 64, # 65 Exhibit 65, # 66 Exhibit 66, # 67 Exhibit 67, # 68 Exhibit 68, # 69 Exhibit 69, # 70 Exhibit 70, # 71 Exhibit 71, # 72 Exhibit 72, # 73 Exhibit 73, # 74 Exhibit 74, # 75 Exhibit 75, # 76 Exhibit 76, # 77 Exhibit 77, # 78 Exhibit 78, # 79 Exhibit 79, # 80 Exhibit 80, # 81 Exhibit 81, # 82 Exhibit 82, # 83 Exhibit 83, # 84 Exhibit 84, # 85 Exhibit 85, # 86 Exhibit 86, # 87 Exhibit 87, # 88 Exhibit 88, # 89 Exhibit 89, # 90 Exhibit 90, # 91 Exhibit 91, # 92 Exhibit 92, # 93 Exhibit 93, # 94 Exhibit 94, # 95 Exhibit 95, # 96 Exhibit 96, # 97 Exhibit 97)(Ellsworth, Felicia)

EXHIBIT 34

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

STUDENTS FOR FAIR ADMISSIONS,
INC.,
Plaintiff,
v.
PRESIDENT AND FELLOWS OF
HARVARD COLLEGE (HARVARD
CORPORATION),

)
)
)
)
)
)
)
)
)
)
)
)

Civil Action No. 1:14-cv-14176

Defendant.

REPORT OF RUTH SIMMONS, Ph.D.
December 15, 2017

TABLE OF CONTENTS
I.

INTRODUCTION ....................................................................................................................1

II.

ASSIGNMENT ........................................................................................................................5

III.

DIVERSITY OF ALL KINDS, INCLUDING RACIAL DIVERSITY, ENRICHES
INSTITUTIONS OF HIGHER LEARNING AND BENEFITS SOCIETY .......................................6

IV.

GIVEN HARVARD’S IMPORTANT GOALS IN ASSEMBLING AN OUTSTANDING AND
DIVERSE STUDENT BODY, IT APPROPRIATELY CONSIDERS STUDENTS’
BACKGROUNDS AND EXPERIENCES, NOT JUST THEIR ACADEMIC
ACHIEVEMENTS, IN ITS ADMISSIONS DECISIONS .............................................................14

V.

HARVARD HAS DISPLAYED A CONSIDERABLE COMMITMENT TO UNLOCKING
THE BENEFITS OF DIVERSITY ..........................................................................................16

VI.

VARIOUS ADMISSIONS PRACTICES THAT HAVE BEEN CRITICIZED SERVE
IMPORTANT AND LEGITIMATE UNIVERSITY INTERESTS .................................................20

I. INTRODUCTION
1. I have been retained by the President and Fellows of Harvard College (“Harvard”) to
provide an expert opinion in this matter. Based on my own experience as a professor and
administrator of institutions of higher education and in leadership roles with non-profit and forprofit institutions, and my review of the materials cited herein, I conclude that the attainment of a
diverse (including a racially diverse) student body contributes to the depth of education afforded
students, enriches the campus environment, prepares students for engagement in a complex
world after their graduation, and benefits our society.
A. Professional Experience and Qualifications
2. I have spent more than forty years working in American higher education at
institutions across this country.

I have held several leadership roles, including at Brown

University, where I led the university for more than a decade as President; Smith College, where
I was President for six years; Princeton University, where I spent ten years in various roles in the
administration including Vice Provost and Associate Dean of the Faculty; and Spelman College,
where I was Provost. I have also been a professor at several universities. I am presently the
President of Prairie View A&M University in Prairie View, Texas.
3. In addition to my leadership positions at institutions of higher education, I have served
on the boards of several major American and international companies, including Texas
Instruments, Pfizer, MetLife, Mondelez International, and Goldman Sachs. I currently serve on
the boards of Fiat Chrysler Automobiles and financial services and mobile payment company
Square, Inc.
4. I have also held numerous leadership roles with several non-profit organizations in the
fields of education, the arts, and government. I have served as a Trustee of Princeton University,
the Carnegie Corporation of New York, Rice University, Dillard University, and Howard

1

University. I am a member of the Museum Council of the Smithsonian’s National Museum of
African American History and Culture, and I am a fellow of the American Academy of Arts and
Sciences. I am also a member of the American Philosophical Society and the Council on
Foreign Relations.

I served on the President’s Commission on White House Fellowships

between 2009 and 2014. I presently chair the board of the Holdsworth Center, a non-profit entity
that provides training and leadership development to public school district administrators.
5. I have received numerous honors throughout my career. I hold more than 40 honorary
degrees from academic institutions around the world, including the University of Oxford and
Harvard University. I have been named a “chevalier” in the French Legion of Honor. I have
served as a keynote speaker at the United Nations General Assembly, at the World Economic
Forum at Davos, at the Washington Ideas Forum, and before many other distinguished
audiences. I was named a Woman of the Year by CBS in 1996, by Ms. magazine in 2002, and
by Glamour magazine in 1996 and 2007. In 2001, I was named America’s “best college
president” by Time magazine.

I received a ROBIE Humanitarian Award from the Jackie

Robinson Foundation, the Ellis Island Medal of Honor, the American Foreign Policy Association
Medal, and many other awards.
6. Based on my decades of experience leading institutions of higher education, I am
familiar with the benefits to universities and their students when those institutions have and value
diversity in their student bodies. Those benefits include both the quality of education that
students receive when they engage on campus with other students from varied backgrounds and
the way that a diverse student body prepares those students for life after college. In addition,
from my experience serving on the boards of major corporations and holding a variety of
positions in non-profit organizations, I understand how businesses, non-profit organizations, and

2

government value and benefit from diversity in our increasingly pluralistic society, and also
value and benefit from students who have been exposed to and engaged with students from
varied backgrounds during their college experience.
7. I have learned first-hand about the invaluable lessons students gain when interacting
with others who come from different backgrounds. My own experiences interacting with people
from different backgrounds have influenced me profoundly, just as those experiences have the
potential to influence college students today.
8. Until I attended college, I had very little exposure to anyone from backgrounds
different from mine. I was born in the small town of Grapeland, Texas, in 1945, the youngest of
twelve siblings. My father was a sharecropper, and we lived as tenants on a former cotton
plantation with other African-American families. When I was seven years old, our family moved
to Houston, Texas, where my father worked in a factory and my mother worked as a maid. We
lived in the Fifth Ward, which was deeply segregated, and I attended segregated elementary,
middle, and high schools. I had no interactions with people of different racial, cultural, or
economic backgrounds in my childhood.
9. In 1967, I earned a B.A. degree in French from Dillard University, a historically black
liberal arts college in New Orleans, Louisiana, graduating summa cum laude. It was during my
college years that I first had sustained, meaningful interactions with white people. I spent my
entire junior year at Wellesley College in Massachusetts. I also spent a summer studying
Spanish in Saltillo, Mexico, where I lived with a Mexican family. After graduating from college,
I spent a year studying at the Université de Lyon in France as a Fulbright Scholar.
10. After college, I worked for the United States Department of State. I then earned a
master’s degree and doctorate in Romance Languages and Literatures from Harvard University.

3

11. While I attended graduate school at Harvard, I served as an undergraduate
admissions officer at Radcliffe College from 1970 to 1972.
12. Following my doctorate, I began my career in academia, including several leadership
positions at institutions of higher education, where I was responsible for many aspects of the
student experience and the educational development of students. I first spent a decade at the
University of New Orleans, California State University – Northridge, and the University of
Southern California. Between 1979 and 1983, I served as Assistant Dean and then Associate
Dean of the Graduate School at the University of Southern California.
13. In 1983, I joined the administration of Princeton University, and served in various
roles including Associate Dean of the Faculty. I left Princeton in 1990 to become Provost at
Spelman College, and returned to Princeton in 1992 to serve as Vice Provost, a position I held
for three years.
14. In 1995, I was appointed the ninth President of Smith College. I was the first
African-American woman to run a major private college or university in this nation. I served as
President of Smith College for six years.
15. In 2001, I was appointed the eighteenth President of Brown University, serving as
the first African-American president of an Ivy League university. I led Brown for more than a
decade before stepping down in 2012. At that time, I was named President Emerita of Brown
University. From 2012 to 2014, I was also a Professor of Comparative Literature and Africana
Studies at Brown.
16. In 2017, I was named the Interim President, and then formally appointed as
President, of Prairie View A&M University, a historically black public university in Prairie
View, Texas.

4

17. Further details on my background and qualifications are set out in my curriculum
vitae, which is attached as Exhibit A to this report.
B. Prior Expert Testimony
18. I have never provided deposition and/or trial testimony as an expert in any litigation
or arbitration proceeding.
C. Compensation
19. For my work in connection with this litigation, I am being paid $500 per hour, as
well as reimbursement of any expenses. My compensation is in no way dependent on my
opinions rendered or the outcome of this litigation.
D. Materials Considered
20. In rendering the opinions and conclusions expressed in this report, I have considered
the materials set forth in Exhibit B, in addition to my own professional and personal experience
over the past several decades.
II. ASSIGNMENT
21. I have been asked by Harvard to provide my opinion as to (1) the benefits to
students, universities, and our greater society that flow from the attainment of diversity in an
undergraduate student body; and (2) whether certain admissions practices at Harvard and other
selective institutions of higher learning should be changed or eliminated in order to further the
goal of obtaining a diverse student body.
22. I reserve the right to supplement and modify this statement of my opinions in this
matter, including in response to additional opinions advanced by experts retained by Students for
Fair Admissions, Inc.

5

III. DIVERSITY OF ALL KINDS, INCLUDING RACIAL DIVERSITY, ENRICHES INSTITUTIONS OF
HIGHER LEARNING AND BENEFITS SOCIETY
23. It is my opinion based on my four decades of experience in leadership positions in
higher education, as well my as extensive service on the governing bodies of non-profit and forprofit organizations, that a student body that is diverse in many ways—including racially
diverse—enriches our institutions of higher learning and provides benefits to students that
influence them long after graduation. I have seen and experienced these benefits in my own
career at various colleges and universities, and in my work for a variety of corporations and
organizations.
24. Diverse institutions of higher education are essential in today’s society. American
institutions of higher learning, including Harvard, aim to educate leaders who will be valuable
contributors to our institutions and communities and citizens who will enhance and exemplify
the ideals of the democratic way of life in America.

Indeed, Harvard College’s mission

statement begins by stating that “The mission of Harvard College is to educate the citizens and
citizen-leaders for our society.” Harvard College, Mission.1
25. Harvard’s mission statement also states that Harvard seeks to achieve its mission
through “the transformative power” of a liberal arts education. Based on my experience and
observation over decades in higher education, I can confidently say that diversity is central to
“the transformative power” of education on college campuses like Harvard’s. Interactions with
diverse peers challenge students’ pre-existing assumptions, teach students about the importance
of different perspectives and lived experiences, and help students learn to communicate across
differences.

1

As Harvard states, its “undergraduate curriculum is deliberately shaped to

Available at: https://college.harvard.edu/about/mission-and-vision.

6

encourage exposure to ‘new ideas, new ways of understanding, and new ways of knowing.’”
2016 Report of the Committee to Study the Importance of Student Body Diversity, chaired by
Dean of Harvard College Rakesh Khurana (“Khurana Report”) (Exhibit C) at HARV00008054.
26. A persisting reality is that many of our nation’s high school students do not
meaningfully interact with people who reflect the diversity of backgrounds, opinions, and lived
experiences representative of the complex richness of our nation and world. In fact, many high
school students attend schools and live in communities that are relatively homogeneous. Orfield
et al., E Pluribus… Separation: Deepening Double Segregation for More Students, The Civil
Rights Project (Oct. 2012).2 This lack of experience with different types of people is a leading
reason that students on college campuses often hear (and complain about) hurtful comments
from peers regarding their background or appearance. Students who lack previous experience
interacting with people from different backgrounds often lack the perspective and skill required
to communicate effectively across significant differences. They make uninformed or hurtful
comments, often without intending to do so. In many cases, attending college—especially a
college with a richly diverse student body—helps students acquire the perspective and skill
required to interact with people vastly different from themselves.
27. College is, for many students, one of the first times that they will live, eat, study, and
socialize in close quarters with people whose lived experience differs vastly from their own. Just
as exposure to new ideas from learned faculty is central to the college experience, so too is the
experience of interacting with and learning from different types of people. Public statements by

2

Available at: https://www.civilrightsproject.ucla.edu/research/k-12-education/integration-anddiversity/mlk-national/e-pluribus...separation-deepening-double-segregation-for-morestudents/orfield_epluribus_revised_omplete_2012.pdf.

7

Harvard’s leaders are consistent with my experience. For example, as Harvard’s President Drew
Faust explained in 2015, “for many if not most of those arriving at Harvard for the first time, this
is the most varied community in which they have ever lived—perhaps ever will live. People of
different races, religions, ethnicities, nationalities, political views, gender identities, sexual
orientations.

We celebrate these differences as an integral part of everyone’s education.”

President Drew Faust, 2015 Remarks at Morning Prayers (Sept. 2, 2015).3 Likewise, Harvard
has explained that by putting people with different ideas and experiences “on the other side of
the seminar table—and in one’s own dormitory rooms and dining halls—we ensure that our
students truly engage with other people’s experiences and points of view, that they truly develop
their powers of empathy.” Khurana Report at HARV00008052.
28. Diversity of all kinds, including racial diversity, is essential to students’ higher
education experience and the pedagogical goals of Harvard and other institutions. It provides all
students with a rich and rewarding educational experience. In interacting with each other both
inside and outside the classroom, students who come from diverse backgrounds and experiences
challenge ideas, preconceptions, and stereotypes. That interaction and learning occurs both
formally in the classroom and informally—in dormitories and dining halls, through participation
in campus organizations and sports, and through the myriad other encounters that occur when
students share the same campus for years. As Harvard College’s mission explains: “Beginning
in the classroom with exposure to new ideas, new ways of understanding, and new ways of
knowing, students embark on a journey of intellectual transformation. Through a diverse living
environment, where students live with people who are studying different topics, who come from

3

Available at: https://www.harvard.edu/president/speech/2015/2015-remarks-morning-prayers.

8

different walks of life and have evolving identities, intellectual transformation is deepened and
conditions for social transformation are created.” Harvard College, Mission.
29. My experience has led me to understand the many ways in which diversity
contributes to classroom learning. Faculty and students are exposed to new ideas, different
perspectives and ways of thinking, and new subjects of academic inquiry that would not exist in
a monocultural institution. In posing different questions, students and faculty invariably find
different answers.

Cultural institutions within the university produce more innovative and

exciting material.

All of this makes diverse universities more dynamic, vibrant places of

learning and inquiry.
30. Outside the classroom, students’ interactions with others who have had different
lived experiences enrich a campus community with energy and constant discovery. Whether it is
learning how to live and share space with a roommate from a completely different walk of life,
discussions over meals at the dining hall, or expressing a shared interest or talent on the stage or
on the field, a campus and its students thrive when people learn to come together so that they
may learn from each other.
31. As students of different backgrounds interact on campus, they often recognize
unexpected similarities and shared interests, forging relationships across all sorts of differences.
As these relationships and interactions become more frequent and deepen, students make
unexpected discoveries about themselves, others, and the world.

These interactions across

difference can break down stereotypes that are based on assumptions, rather than information.
32. Uncomfortable interactions on the basis of differences rather than similarities can
also be influential and valuable.

I often tell my students that learning about—and being

confronted with—someone else’s lived experience, insights, and opinions can change not only

9

what you think, but how you think. For example, I was profoundly affected as an undergraduate
student by a discussion of South African apartheid in a philosophy class at Wellesley College.
My strongly felt opposition to apartheid was influenced by my experience as a black woman
growing up and going to school in a segregated system in Texas. As the teacher sought student
input, many other students expressed views similar to mine. Then, a white classmate revealed
that she was South African and proceeded to talk about her own experience with apartheid. She
offered an explanation and defense of apartheid that I disagreed with vehemently. I found
remarkable not only how people could see social and cultural phenomena and political
environments in such different ways, but also how they could rely on those views to justify
vastly different beliefs and choices. It was a formative moment that caused me to think about the
value of being able to talk to someone with an immensely different background and worldview, a
value that I have carried with me since. I began to see that encountering someone from a
different background or perspective with whom I sharply disagree is not counter-productive.
Learning to do so with equanimity is a bed-rock need in a diverse nation. It is important to see
different perspectives, test one’s thoughts, and thereby apprehend the complex variety of
experiences that shape individual and group views in our nation.
33. Another example of this type of uncomfortable interaction across difference occurred
when the writer David Horowitz planned to speak at Brown while I was President. Horowitz had
engendered substantial controversy on campus by expressing provocative—and in my view, very
offensive and entirely wrong—thoughts about the impact of slavery. My response was to attend
Horowitz’s speech. I hoped to encourage students to attend, to listen, and to question Horowitz
so they could get a perspective on this complex person with misguided, but sincerely held, views.
I doubted that many students would be persuaded by Horowitz’s talk, but I thought—and

10

continue to think—that it is essential to hear speech from those with different viewpoints,
including provocative speech.

That can lead to the crystallization or sharpening of an

individual’s perspective, to productive and enlightening discussion about the provocative speech,
and to greater awareness of the world’s complexity.
34. As it was for me in this instance, students’ interactions with people different from
themselves are often more memorable and instructive than engaging with people who have
similar backgrounds and are like-minded. Although learning about the experiences and views of
others in lecture halls and books has great value, nothing can fully substitute for the impact of
personal interaction and observation. My experience as an administrator confirms that alumni
invariably think back on formative relationships, conversations, and interactions with fellow
students and professors that shaped their views and lives. Based on my innumerable interactions
with alumni of many different institutions, I am aware that when alumni reflect on the
experiences that most profoundly affected them or shaped their lives, it is rarely a book or lecture
that they reference. Rather, alumni most frequently remember and talk about eye-opening
experiences, conversations, or friendships with fellow students or mentors.
35. The benefits that students receive from being part of a diverse student body does not
stop when they graduate. Quite the contrary: The rich experiences that students receive as
undergraduates prepare them for working in a complex nation and world and shape their outlook
as they take their place as engaged citizens and leaders in our society. Indeed, a crucial task that
our universities face today is one that our leading institutions have faced throughout history:
providing students with the knowledge and skills to be actively engaged citizens who will define
the principles of the nation and to lead its diverse and important institutions and communities.
Our nation’s founders recognized that leaders would require education and experience for the

11

nation to be successful. John Adams questioned whether our nascent country had sufficient
leaders “fit for the times” and worried that the country’s leaders were “deficient in genius,
education, in travel, fortune—in everything.” McCullough, John Adams, 23 (2001).
36. Based on my experience, leading universities must play a central role in producing
leaders “fit for the times”—and universities like Harvard consistently and rightly embrace that
mission. Few other institutions are as capable of doing so. Harvard has rightly recognized
that—in order to produce such leaders, and to fulfill its mission of educating “the citizens and
citizen-leaders for our society”—diversity must play a central role in the college experience.
Universities like Harvard recognize that our strength comes from breadth and openness, and that
when we retreat to enclaves of thought or bias, we will fall short of achieving the highest
possibilities for the union. Successful citizens and citizen-leaders must be aware of the complex
richness of humanity and they must have the skills required to reach across differences and
stereotypes to communicate with others and engage the world around them.
37. Regardless of race, the leaders of our nation’s communities and institutions must be
able to lead conversations and work with people vastly different from themselves in terms of
background and opinion. That is not an innate skill; it must be learned, honed, and practiced.
Our institutions of higher education can and must play a central role in preserving and enhancing
this skill. Indeed, universities are already recognized as leaders in this area, which is why I and
other university leaders speak to a broad spectrum of groups about how to achieve this goal.
38. Based on my experience in leadership at American universities, sitting on the boards
of directors of numerous publicly-traded corporations, and serving as a director and leader for a
variety of non-profit institutions, I am aware that it is essential that institutions of all kinds have
diverse leadership. Institutions in all fields—whether for-profit, non-profit, or governmental—

12

make better decisions and produce better outcomes when they have diverse leaders and
members.
39. My experiences on the board of directors for major multinational corporations,
including Pfizer, Fiat Chrysler, Mondelez, and many other companies confirm the importance of
diversity and the ability to interact across differences in business leadership. Our leading
businesses understand that diverse organizations make better decisions and achieve greater
success. Accordingly, they focus considerable resources on recruiting and retaining a diverse
workforce, management team, and board. For example, Intel recently announced a substantial
investment designed to diversify its workforce and Pepsi CEO Indra Nooyi described
diversifying the workforce as “a business imperative.” 4

Particularly in the crucial area of

corporate leadership, it is essential to the future of the American economy that our top
universities produce graduates who are prepared to take on leadership roles in diverse
organizations that serve diverse populations. If universities falter in preparing students for these
roles, leading institutions will not have the expertise to accomplish these goals.
40. My experience as a director and leader for various non-profit entities (aside from
colleges and universities) and programs, including the National Museum of African American
History and Culture, the Houston Museum of Fine Arts, and the Holdsworth Center, likewise
confirms the importance of diversity and the ability to communicate across difference in the nonprofit sector. Non-profit organizations, of course, define their missions in many different ways.

4

Wingfield, “Intel Allocates $300 Million for Workplace Diversity,” N.Y. Times (Jan. 6, 2015),
available at: https://www.nytimes.com/2015/01/07/technology/intel-budgets-300-million-fordiversity.html; Clifford, “PepsiCo CEO: Hiring more women and people of color is a ‘business
imperative,’” CNBC (Oct. 17, 2016), available at: https://www.cnbc.com/2016/10/17/pepsicoceo-hiring-more-women-and-people-of-color-is-a-business-imperative.html.

13

Many non-profits have broad missions, diverse membership, and face the challenge of being
responsive to diverse communities. Even in non-profits with less diverse membership and
leadership, it is essential that leaders understand how to respond to and engage with our diverse
society.
41. Ultimately, Harvard’s institutional judgment that diversity is essential to its mission
and pedagogical goals is consistent with my observations after a career in higher education that
campus diversity yields a variety of important benefits for students and for our society.
IV. GIVEN HARVARD’S IMPORTANT GOALS IN ASSEMBLING AN OUTSTANDING AND DIVERSE
STUDENT BODY, IT APPROPRIATELY CONSIDERS STUDENTS’ BACKGROUNDS AND
EXPERIENCES, NOT JUST THEIR ACADEMIC ACHIEVEMENTS, IN ITS ADMISSIONS DECISIONS
42. As noted above, Harvard and other colleges and universities view their educational
mission not just as providing an excellent classroom learning experience—although that is
undoubtedly important—but also in terms of preparing students to contribute to a diverse nation
and world. They encourage rewarding and stimulating interactions among students that teach
valuable lessons and prepare students for participation in democratic society and for leadership
of all manner of institutions.

Harvard and other highly-selective institutions have long

recognized that academic achievement and academic potential should play an important role in
the admissions process. The educational environment at Harvard is strengthened when smart,
inquisitive students are deeply engaged in the classroom, in discussions with fellow students, and
in all manner of independent projects and research. We all benefit from educated, thoughtful
citizens and leaders who are continually engaged and motivated to learn and share their insights.
Yet highly selective institutions of higher education like Harvard rightly consider more than a
student’s academic achievement and academic potential in deciding whom to admit.

14

43. In assembling the student body, highly selective universities like Harvard will have
far more applicants who are capable of academic success than they will have places for
admission. For the Class of 2021, more than 39,000 students applied to Harvard, around 2,000
applicants were admitted, and roughly 1,700 students enrolled. Admissions Statistics, Harvard
College.5 In such a competitive field, Harvard will face choices among thousands of applicants
with similarly strong academic qualifications.
44. Based on my experience, it is my opinion that, when selecting among those students,
universities benefit when they fill their classes with students who have diverse backgrounds and
perspectives, and students who are ready and willing to engage with others. This includes
students who have taken advantage of any opportunities available to them to reach beyond their
own interests to learn about and work with the other people, subjects, and environments that
surround them. While the range of opportunities available to each student will vary widely, a
careful admissions process should be able to identify students who have maximized
opportunities, demonstrated a desire to expand horizons, shown the ability to connect with
others, and had experiences that will contribute to the richness of the university community.
45. The goal of highly selective colleges like Harvard is not to assemble the class with
the highest possible average GPA; it is to assemble a vibrant, diverse community on campus
where students are able to thrive individually and learn from their peers, instead of retreating into
sequestered groups formed around similarity or routine and familiar ways of thinking. Full
participation in such an environment provides the most enriching educational experience

5

Available at: https://college.harvard.edu/admissions/admissions-statistics.

15

possible, and prepares graduates for success and leadership in numerous fields of endeavor and
communities.
46. In my work as a Commissioner on the Commission on White House Fellowships and
as Chair of the Northeast Region Selection Committee for the Rhodes Scholarship, I helped
select some of our nation’s most talented and promising young leaders for prestigious programs
that would provide them with additional knowledge, experience, and skills. We sought people
with outstanding academic credentials, of course. But there were always more people with
impressive intelligence and academic credentials than there were spots available. We sought to
identify people from a variety of different backgrounds and with interest and experience in
different disciplines whose interviews, resumes, essays, recommendations, and other application
materials suggested that they had already and would continue to contribute to their communities
as thoughtful, engaged leaders, bringing fresh ideas and different perspectives to the world’s
problems.
V. HARVARD HAS DISPLAYED A CONSIDERABLE COMMITMENT TO UNLOCKING THE
BENEFITS OF DIVERSITY
47. I understand that universities are sometimes criticized for admitting a diverse class
and then doing little to secure the benefits of diversity once students arrive on campus. If true,
that would be a valid criticism. But based on my understanding of Harvard’s approach to
undergraduate education and a variety of different policies, the criticism is not valid with respect
to Harvard. To the contrary, Harvard has recognized that it is not enough simply to admit a
diverse class and hope that students will find opportunities to engage with each other; rather, it
has taken concrete steps to make sure that engagement occurs.
48. Harvard stands out among American colleges in that 97 percent of its students live
on campus for the entire time they attend. Khurana Report at HARV00008059. Rather than

16

allowing students to choose their on-campus or off-campus housing, the vast majority of
Harvard’s students live together in freshman dormitories assigned by Harvard and then in one of
Harvard’s twelve residential Houses, for which assignments are random.
a.

Freshman housing is carefully assigned by the Freshman Dean’s office to ensure
that the dorms reflect the diversity of talents and backgrounds in the incoming
class.

Khurana Report at HARV00008059.

It is through this process that

Facebook founder Mark Zuckerberg ended up sharing a freshman dorm room
with Haitian Olympic triple jumper Samyr Lainé. Id. at HARV00008060.
b.

After freshman year, students are randomly assigned to a residential House for the
three remaining years (though they may elect to be assigned within a block of up
to eight students). Each House has its own dining facility and hosts a wide variety
of social, cultural, and educational events throughout the academic year.

c.

In the 1990s, Harvard made a considered—and, at the time, controversial—choice
to assign students to Houses randomly in order to ensure that its Houses reflected
the diversity of the campus community. Id. at HARV0000860-0000861. The
random assignment policy ensures that students are given the opportunity to
interact across difference throughout their time on campus. Such a decision
underscores the commitment of the university to the benefits of diversity.

49. Extracurricular and athletic activities at Harvard also reflect and enhance the
diversity of the Harvard community.
a.

On Harvard’s athletic teams, students of all backgrounds spend countless hours
together, focused on achieving a common goal. Id. at HARV0000862. The

17

athletic teams also bring the university community together at games and
competitions throughout the school year.
b.

Harvard’s extracurricular activities are varied and numerous, again reflecting the
diverse talents, passions, and interests of its students. Students of all backgrounds
are brought together through shared interests in religion, music, technology,
debate, journalism, drama, and countless other areas, and these groups enable
students of all backgrounds to develop and share their talents and interests with
the broader campus community. Harvard College, Admissions & Financial Aid,
Student Activities.6

As students meet their classmates in these less formal

environments, they may learn that “there is no substitute for lived experience to
inform a person’s point of view, or for direct contact with people to understand
their perspectives.” Khurana Report at HARV00008061.
c.

Harvard sponsors more than 50 cultural, ethnic, and international organizations
that enable students to explore and share their cultures with students of similar
backgrounds and with the broader community. Harvard College, Admissions &
Financial Aid, Student Activities. Harvard’s sponsorship of these groups also
reflects the university’s recognition of the diversity—and the value of that
diversity—within its ranks.

50. In my experience, universities are far more successful in unlocking the benefits of
diversity when they have faculty and staff members who are committed to that goal. The
existence of positions supporting diversity demonstrates to all community members that the

6

Available at: https://college.harvard.edu/admissions/choosing-harvard/student-activities.

18

university cares about diversity, and the work of those employees encourages the type of
interaction across difference that yields important benefits.

Harvard has displayed its

commitment to unlocking the benefits of diversity through hiring and other initiatives. For
example, Harvard’s Office for Equity, Diversity, and Inclusion and the Harvard Foundation have
multiple staff members who are devoted to ensuring that Harvard’s diversity is enhanced and that
students can have the meaningful interactions that advance the university’s goals.
51. Harvard has also committed substantial institutional resources to understanding the
role that diversity plays on campus and how it may be improved. Harvard College convened a
Working Group on Diversity and Inclusion in 2014 that sought to “assess Harvard College’s
learning environment in order to ensure that all students benefit equally from its liberal arts
educational and service mission.” Report of the College Working Group on Diversity and
Inclusion, Harvard University (Nov. 2015), at 7.7 In 2016, Harvard President Drew Faust
convened a Presidential Task Force on Inclusion and Belonging charged with “making sure that
Harvard continues to attract the most talented people from all walks of life and creates an
environment where we can be our best selves.” Charge, Presidential Task Force on Inclusion
and Belonging, Harvard University (2016).8
52. Building a thriving, diverse community is an ongoing process—there are and will be
tough conversations and conflicts along the way, as there have been at Harvard. But it is too
simplistic to dismiss the real educational benefits of a diverse college community by pointing to
the existence of conflicts on campus. Rather, when students show they do not yet understand

7

Available at: http://diversity.college.harvard.edu/files/collegediversity/files/diversity_and
_inclusion_working_group_final_report_2.pdf.
8
Available at: https://inclusionandbelongingtaskforce.harvard.edu/task-force-charge.

19

how to respond to people with sharply different perspectives, backgrounds, and experiences, that
is an opportunity for universities to help them learn.

Harvard has displayed a genuine

commitment to ensuring that it is a community where everyone can share opinions and
experiences, ask tough questions, and collectively search for greater knowledge and
understanding. This is seen in the recent Working Group on Diversity and Inclusion and the
Presidential Task Force on Inclusion and Belonging. It is seen repeatedly in the statements of
Harvard’s leaders. And it is seen in the faculty’s recommitment to the centrality of diversity to
Harvard’s liberal arts education.
53. The existence of and open discussion of conflicts, and the way that Harvard has
addressed them, reveal a university that is committed to its diversity goals and its broader
mission.

Harvard has recognized that there is no simple policy that will maximize the

educational value of diversity; rather, it is an ongoing process that requires constant thought and
attention. Harvard has shown itself to be committed to that project.
VI. VARIOUS ADMISSIONS PRACTICES THAT HAVE BEEN CRITICIZED SERVE IMPORTANT
AND LEGITIMATE UNIVERSITY INTERESTS
54. I am aware that there are criticisms of some admissions practices used by Harvard
and many other colleges and universities that allegedly inhibit the effort to ensure diversity on
campus.

Harvard and many other universities face criticism for considering athletic

achievement, legacy status, and whether an applicant is the child of university faculty or staff.
They also face criticism for maintaining early action admission policies.

Based on my

experience, all of these considerations and policies—which are common at universities across
the United States—bring about important, legitimate benefits.
55. There would be substantial costs if Harvard were to stop considering whether
applicants are the children of alumni. In my experience, universities are stronger and more

20

successful when they have strong networks of loyal alumni who continue to view themselves as
members of the university community long after graduation. Universities do not want graduates
to simply think of themselves as passing through campus for a few years. Private universities, in
particular, depend on the continued engagement and participation of their alumni in recruiting
and interviewing candidates, fundraising, networking for recent graduates, participating in local
alumni groups, and countless other activities. Paying attention to legacy status in admissions can
play an important role in maintaining alumni allegiance and interest. Alumni remain engaged
with their alma mater for many reasons, but based on my experience with alumni of many
institutions of higher education, I can say that one reason they do so is that some alumni have an
interest in having their children attend their alma mater and think their children will have a real
opportunity to attend. I do not believe this impulse is pernicious; it is based on genuine ties of
affection that alumni have with their alma mater. As long as the applicants admitted under such
policies are genuinely qualified at the high level universities expect of all their students, and as
long as the applicants can be reasonably expected to make substantial contributions to the
university community in their own right, there are good policy-based reasons for universities to
consider whether applicants are the children of alumni.
56. Based on my experience at a variety of different universities, there are also strong
reasons for universities to consider whether an applicant’s parents work at the university to
which an applicant has applied.

In my experience, this type of policy typically affects only a

small number of applications in any given year. That is, eliminating consideration given to the
children of faculty and staff would be unlikely to yield any meaningful benefit to campus
diversity while it would threaten to impose substantial costs in terms of faculty and staff morale.
Universities are made stronger when their employees are engaged, happy, and fully invested in

21

the success of the institution. Moreover, the market for top faculty, staff, and administrators is
quite competitive. Giving consideration to the children of employees can be important to
retaining the people who work so hard to make our universities great, and it can deepen their
loyalty to the university. As long as the applicants admitted under such policies are qualified
academically and otherwise, and as long as they will bring to the campus the willingness to
engage broadly that universities expect of all students, there are good policy-based reasons for
universities to afford consideration to the small number of applicants who fall into this category.
57. Based on my many decades of experience in higher education, it is also clear to me
that athletics plays an important role on college campuses in the United States.

Athletic

competition is a deeply engrained part of the history and traditions at many of our nation’s finest
institutions of higher education, including Harvard. University sports bring students together and
bring alumni back to campus throughout the year. The unique contributions that athletes make to
the campus community, combined with the talent and dedication demonstrated by athletes good
enough to be recruited, are legitimate reasons to consider athletic talent in admissions decisions,
so long as those admitted on that basis are also capable of succeeding academically and
contributing to the campus community in other ways.
58. It is my opinion that eliminating early action admissions would have substantial costs
for a university like Harvard. Early action gives students an opportunity to demonstrate their
considered interest in a particular university, which is important information to have in the
admissions process.

In addition, early action is very important in recruiting some of the

strongest students. In my opinion, and based on my experience at Brown when the elimination
of early action was considered, any potential benefits from eliminating early action would
outweigh the potential costs of losing out on some of our most talented students. While I am

22

aware of the suggestion that early action programs may unfairly advantage certain applicants,
this is an issue that universities may address by ensuring that information about admissions
policies is well publicized, and through admissions decisions themselves.

23

24

EXHIBIT A

RUTH J. SIMMONS
PRESIDENT, PRAIRIE VIEW A&M UNIVERSITY
OFFICE ADDRESS

Ruth J. Simmons
President, Prairie View A&M University
P.O. Box 519; MS 1001
Alvin I. Thomas Bldg.
Suite 202
Prairie View, TX 77446

EMPLOYMENT HISTORY
PRAIRIE VIEW A&M UNIVERSITY, President, 2017 BROWN UNIVERSITY, President Emerita, 2014 - present
BROWN UNIVERSITY, President Emerita and Professor of Comparative Literature,
2012 - 2014
BROWN UNIVERSITY, President and Professor of Comparative Literature and
Africana Studies, 2001 - 2012
SMITH COLLEGE, President Emerita, July 2001 - present
SMITH COLLEGE, President, July 1995 - June 2001
PRINCETON UNIVERSITY, Vice Provost, January 1992 - July 1995
SPELMAN COLLEGE, Provost, January 1990 - December 1991
PRINCETON UNIVERSITY, Associate Dean of the Faculty, 1986-1990; Assistant Dean
of the Faculty, 1986-87; Acting Director, Afro-American Studies, 1985-87; Director of Studies,
Butler College, 1983-85
UNIVERSITY OF SOUTHERN CALIFORNIA, Associate Dean of the Graduate School,
1982-83; Assistant Dean of the Graduate School, 1979-82
CALIFORNIA STATE UNIVERSITY- NORTHRIDGE, Acting Director of International
Programs and Visiting Associate Professor of Pan-African Studies, 1978-79; Administrative
Coordinator, NEH Liberal Studies Project, 1977-78
UNIVERSITY OF NEW ORLEANS, Assistant Dean of the College of Liberal Arts
1975-76; Assistant Professor of French, 1973-76

1

RUTH J. SIMMONS
RADCLIFFE COLLEGE, Admissions Officer (part-time while a graduate student),
1970-72
GEORGE WASHINGTON UNIVERSITY, Instructor in French (while enrolled as a
graduate student), 1968-69
LANGUAGE SERVICES DIVISION - U.S. DEPARTMENT OF STATE, Interpreter,
1968-69
EDUCATION
Ph.D.; A.M.

1973; 1970

Université de Lyon
B.A.

Harvard University
Romance Languages and Literatures
George Washington University

1967-68

Dillard University
Wellesley College (visiting junior)
Universidad Internacional, Saltillo

1967
1965-66
Summer, 1965

SELECTED ACADEMIC AWARDS AND HONORS
-Visiting Fellow, London School of Economics, June 2015
-Over Forty Honorary Degrees, including the following:
University of Oxford, 2015
Georgia Institute of Technology, 2013
Brown University, 2012
University of Oklahoma, 2012
Mt. Sinai School of Medicine, 2012
The American College of Greece, 2008
Morehouse College, 2006
Spelman College, 2007
University of Toronto, 2004
Jewish Theological Seminary,
Ewha Women’s University, Korea, 2002
Harvard University, 2002
Columbia University, 2002
NYU, 2001
University of Pennsylvania, 2001
Dartmouth College, 1997
Princeton University, 1996
Dillard University, 1996
Howard University, 1996

2

1968-69

RUTH J. SIMMONS

AWARDS/HONORS
-Named a ‘chevalier’ in the French Legion of Honor. May 2013
-Susan Colver Rosenberger Medal, Brown University, May 2011
-Keynote Speaker, United Nations General Assembly, Special Commemorative Meeting,
March 2011
-American Foreign Policy Association Medal, May 2010
-Ellis Island Medal of Honor, May 2010
-BET Honors Award, January 16, 2010
-A Glamour magazine Woman of the Year, 2007
-Named one of U.S. News & World Report’s top U. S. leaders, 2007
-President’s Medal, Emory University, 2006
-Eleanor Roosevelt Val-Kill Medal, 2004
-Chairman’s Award, Congressional Black Caucus Foundation, 2004
-ROBIE Humanitarian Award, the Jackie Robinson Foundation, 2004
-Ms. Magazine Woman of the Year, 2002
-Drum Major for Justice Award, SCLC/W.O.M.E.N. Inc., 2002
-Fulbright Lifetime Achievement Medal, 2002
-Named America’s “best college president” by Time magazine, 2001
-President’s Award, United Negro College Fund, March 2001
-Teachers College Medal for Distinguished Service, Columbia University, 1999
-National Urban League Achievement Award, November 1998
-Centennial Medal, Harvard Graduate School of Arts and Sciences, 1997
-A Glamour Magazine Woman of the Year, 1996
-An NBC Nightly News Most Inspiring Woman, August 1996
-A CBS Woman of the Year, January 1996
-Fulbright Scholar, Université de Lyon, France, 1967-68
-Danforth Fellow, 1967-73
-Summa cum laude, Dillard University, 1967

MEMBERSHIPS IN HONORARY SOCIETIES
-chevalier, French Legion of Honor
-Alfalfa Club, Washington, D.C.
-Council on Foreign Relations
-American Academy of Arts and Sciences
-American Philosophical Society
-Phi Beta Kappa
-Massachusetts Historical Society

3

RUTH J. SIMMONS
SELECTED PUBLICATIONS / PAPERS
Introduction, Slavery and the University: Histories and Legacies,
(University of Georgia Press, 2018 Forthcoming)
“America’s Relationship with the World: How Can Languages Help?” The French
Review, March 2004, pp. 682-689
Foreword, Meridians: (Inaugural Issue), Autumn 2000
“My Mother’s Daughter: Lessons I Learned in Civility and Authenticity”
Texas Journal of Ideas, History and Culture, Fall/Winter 1998
“Passion, Generosity, and the Academy.” Meridians, Volume 3 Number 1, pp. 42-49
“Recognizing Moments of Learning.” In True to Ourselves, edited by Nancy Neuman,
Jossey-Bass Inc., 1998, pp.16-23
Preface, Professorial Passions, Smith College, 1997
Haiti, A Study of the Educational System and Guide to U.S. Placement, World Education
Series, AACRAO, 1985
“Aime Cesaire: Colonialism and the Poetics of Authenticity.” College Language
Association Journal, 73 (March 1976), pp. 382-88
“La Poesie de David Diop.” Presence Africaine, N.S.F., 73 (3e trimestre, 1970),
pp. 91-96

SELECTED MEDIA FEATURES / PUBLISHED INTERVIEWS
Today Show appearance with Meredith Vieira regarding Newsweek’s special issue on
Women and Leadership, September 19, 2006
“Lessons We Have Learned”, Newsweek Magazine interview on Women and Leadership,
September 2006
“Doing It Right Matters,” as told to Glenn Rifkin in the Boss Column, New York Times,
February 5, 2006
“Peculiar Institutions: Brown University looks at the slave traders in its past,” by Frances
Fitzgerald, The New Yorker, September 12, 2005, pp. 68-77
“Head of the Class,” by Katy Vine, Texas Monthly, February 2003, pp. 60-63
“The Helping Hand,” by Wallace Terry, Parade Magazine, December 22, 2002, pp. 4-5
The Right Words at the Right Time, edited by Marlo Thomas, Atria Press, 2002,
pp. 314-316
Talking Leadership: Conversations with Powerful Women, edited by Mary Hartman,
Rutgers University Press, 1999, pp. 237-255
Singular Voices: Conversations with Americans Who Make a Difference, Barbaralee
Diamonstein, Harry N. Abrams, Inc., 1997, pp. 111-125

4

RUTH J. SIMMONS
PAPERS / PRESENTATIONS
Selected Invited Lectures/Keynotes:
-Princeton University Wilson College, 2015
-Stanford University School of Medicine, May 2015
-London School of Economics Public Affairs Institute, 2015
-DeLange Conference, Rice University, 2014
-World Economic Forum at Davos, 2012 and 2002
-Brookings Institution Taubman Forum, 2010
-Washington Ideas Forum, 2009
-California Conference on Women, 2009
-California Institute of Technology, 2009
-Economic Club of Washington. 2008
-University of Guadalajara, 2007
-Cambridge University, 2007
-Chatauqua Institution, 2006
-Columbia University, 2007
-Temple Emanu-el Nasher Forum, Dallas, 2005
-International Institute of Madrid, 2005
-Harvard University Phi Beta Kappa Oration, 2003
-Harvard Medical School, 2003
-University of Notre Dame Faculty Convocation, 2003
-White House Millennium Evening, 1999
-Joint Session, Massachusetts Legislature, 1998
-92nd Street Y, 1997
-MIT Sloan School, 1997
Selected Commencement Addresses:
-DePauw, 2015
-LBJ School, University of Texas, 2015
-Smith College, 2014
-University of Oklahoma, 2012
-University of Rochester, 2012
-Mt. Sinai School of Medicine, 2012
-American College of Greece, 2008
-Morehouse College, 2006
-Miami Dade College, 2006
-University of Vermont, 2005
-University of Toronto, 2004
-Jewish Theological Seminary, 2004
-Tougaloo College, 2004
-University of Southern California, 2003
-George Washington University, 2002
-Washington University in St. Louis, 2002

5

RUTH J. SIMMONS
SELECTED BOARDS/COMMITTEES
Chair of the Board, Holdsworth Center, 2016–
Board of Trustees, Museum of Fine Arts, Houston, 2017–
Board of Directors, Square, Inc., 2015–
Board of Trustees, Rice University, 2014–
Board of Trustees, Princeton University, 2012–2016
Board of Directors, Chrysler, LLC, 2012–2014
Board of Directors, FCAU, 2014–
Board of Directors, Mondelez International, 2012–2017
Council of the Smithsonian National Museum of African American History and Culture,
2010–
President’s Commission on White House Fellowships
2009–2014
Board of Trustees, Howard University, 2007–2010
Board of Trustees, Dillard University, 2012–2014
Board of Directors, Alliance for Lupus Research, 2002–2004
Board of Directors, The Goldman Sachs Group, 2000–2010
Advisory Council, Bill & Melinda Gates Millennium Scholars Program,
1999–2001
Board of Directors, Texas Instruments, 1999–2016
Board of Trustees, Carnegie Corporation of New York, 1999–2004
Board of Directors, Pfizer Inc., 1997–2007
Advisory Council, Center for African American Studies, Princeton University
1996–

6

RUTH J. SIMMONS
Board of Directors, JSTOR, 1996–1999
Board of Directors, Metropolitan Life Insurance Company, 1995–2001
Board of Trustees, Institute for Advanced Study, 1995–1998
Board of Trustees, Woodrow Wilson National Fellowship Foundation
1991–1996
Chair, Committee to Visit the Department of Afro-American Studies
Harvard University
1991–1999

7

EXHIBIT B

Expert Report of Dr. Ruth Simmons
List of Materials Considered
1. Rudenstine, Neil L. (1996). The President’s Report on Diversity and Learning: 19931995. Harvard University. [HARV00030365–HARV00030450].
2. Walton, Jonathan L. (November 2015). Report of the College Working Group on
Diversity and Inclusion. Harvard University. [HARV00007944–HARV00007982].
3. Khurana, Rakesh. (2016). Report of the Committee to Study the Importance of Student
Body Diversity. Harvard University. [HARV00008048–HARV00008069].
4. Charge. Harvard University Presidential Task Force on Inclusion and Belonging.
Retrieved from https://inclusionandbelongingtaskforce.harvard.edu/task-force-charge.
5. Draft Report of the Harvard Presidential Task Force on Inclusion and Belonging.
(September 19, 2017). Harvard University Presidential Task Force on Inclusion and
Belonging. Retrieved from
https://inclusionandbelongingtaskforce.harvard.edu/files/inclusion/files/discussion_draft_
executive_summary_9.19.17.pdf.
6. Brief for Harvard University et al. as Amici Curiae, The Regents of the University of
California v. Bakke, 98 S.Ct. 2733 (1978) (No. 76–811), 1976 WL 181278.
7. Brief for Harvard University et al. as Amici Curiae Supporting Respondents, Grutter v.
Bollinger, 539 U.S. 306 (2003) (Nos. 02–241, 02–516), 2003 WL 399220.
8. Brief for Harvard University et al. as Amici Curiae Supporting Respondents, Fisher v.
University of Texas at Austin, 133 S.Ct. 2411 (2013) (No. 11–345), 2012 WL 3527821
[Fisher I].
9. Brief for Harvard University et al. as Amici Curiae Supporting Respondents, Fisher v.
University of Texas at Austin, 136 S.Ct. 2198 (2016) (No. 14–981), 2015 WL 6690032
[Fisher II].
10. Ireland, Corydon. (April 18, 2014). A Q&A forum with the president. Harvard Gazette.
Retrieved from https://news.harvard.edu/gazette/story/2014/04/a-qa-forum-with-thepresident/.
11. Faust, Drew G. (July-August 2014). Letters, the View from Mass Hall: To Sit at the
Welcome Table. Harvard Magazine. Retrieved from
https://harvardmagazine.com/2014/07/to-sit-at-the-welcome-table.
12. Faust, Drew G. (September 2, 2015). 2015 Remarks at Morning Prayers. Harvard
University Office of the President. Retrieved from
https://www.harvard.edu/president/speech/2015/2015-remarks-morning-prayers.

1

13. Mission, Vision, and History. Harvard College. Retrieved from
https://college.harvard.edu/about/mission-and-vision.
14. About. Harvard College Office for Equity, Diversity, and Inclusion. Retrieved from
https://diversity.college.harvard.edu/about.
15. History: Beginning. The Harvard Foundation for Intercultural and Race Relations.
Retrieved from https://harvardfoundation.fas.harvard.edu/beginning.
16. History: Expansion. The Harvard Foundation for Intercultural and Race Relations.
Retrieved from https://harvardfoundation.fas.harvard.edu/expansion.
17. History: Present. The Harvard Foundation for Intercultural and Race Relations.
Retrieved from https://harvardfoundation.fas.harvard.edu/present.
18. Admissions Statistics. Harvard College Admissions & Financial Aid. Retrieved from:
https://college.harvard.edu/admissions/admissions-statistics.
19. Student Activities. Harvard College, Admissions & Financial Aid. Retrieved from:
https://college.harvard.edu/admissions/choosing-harvard/student-activities.
20. Ruder, Debra B. (April 24, 1997). Cultivating Friendship Amid Diversity. Harvard
Gazette. Retrieved from https://news.harvard.edu/gazette/story/1997/04/cultivatingfriendship-amid-diversity/.
21. Orfield, Gary, Kucsera, John, & Siegel-Hawley, Genevieve. (October 18, 2012). E
Pluribus… Separation: Deepening Double Segregation for More Students. The Civil
Rights Project. Retrieved from https://civilrightsproject.ucla.edu/research/k-12education/integration-and-diversity/mlk-national/e-pluribus...separation-deepeningdouble-segregation-for-more-students/orfield_epluribus_revised_omplete_2012.pdf.
22. McCullough, David. (2001). John Adams. Simon and Schuster.
23. Wingfield, Nick. (January 6, 2015). Intel Allocates $300 Million for Workplace
Diversity. The New York Times. Retrieved from:
https://www.nytimes.com/2015/01/07/technology/intel-budgets-300-million-fordiversity.html.
24. Clifford, Catherine. (October 17, 2016). PepsiCo CEO: Hiring more women and people
of color is a ‘business imperative.’ CNBC. Retrieved from:
https://www.cnbc.com/2016/10/17/pepsico-ceo-hiring-more-women-and-people-of-coloris-a-business-imperative.html.

2

EXHIBIT C