Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al
Filing
421
DECLARATION re 412 MOTION for Summary Judgment by Students for Fair Admissions, Inc.. (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, # 98 Exhibit 98, # 99 Exhibit 99, # 100 Exhibit 100, # 101 Exhibit 101, # 102 Exhibit 102, # 103 Exhibit 103, # 104 Exhibit 104, # 105 Exhibit 105, # 106 Exhibit 106, # 107 Exhibit 107, # 108 Exhibit 108, # 109 Exhibit 109, # 110 Exhibit 110, # 111 Exhibit 111, # 112 Exhibit 112, # 113 Exhibit 113, # 114 Exhibit 114, # 115 Exhibit 115, # 116 Exhibit 116, # 117 Exhibit 117, # 118 Exhibit 118, # 119 Exhibit 119, # 120 Exhibit 120, # 121 Exhibit 121, # 122 Exhibit 122, # 123 Exhibit 123, # 124 Exhibit 124, # 125 Exhibit 125, # 126 Exhibit 126, # 127 Exhibit 127, # 128 Exhibit 128, # 129 Exhibit 129, # 130 Exhibit 130, # 131 Exhibit 131, # 132 Exhibit 132, # 133 Exhibit 133, # 134 Exhibit 134, # 135 Exhibit 135, # 136 Exhibit 136, # 137 Exhibit 137, # 138 Exhibit 138, # 139 Exhibit 139, # 140 Exhibit 140, # 141 Exhibit 141, # 142 Exhibit 142, # 143 Exhibit 143, # 144 Exhibit 144, # 145 Exhibit 145, # 146 Exhibit 146, # 147 Exhibit 147, # 148 Exhibit 148, # 149 Exhibit 149, # 150 Exhibit 150, # 151 Exhibit 151, # 152 Exhibit 152, # 153 Exhibit 153, # 154 Exhibit 154, # 155 Exhibit 155, # 156 Exhibit 156, # 157 Exhibit 157, # 158 Exhibit 158, # 159 Exhibit 159, # 160 Exhibit 160, # 161 Exhibit 161, # 162 Exhibit 162, # 163 Exhibit 163, # 164 Exhibit 164, # 165 Exhibit 165, # 166 Exhibit 166, # 167 Exhibit 167, # 168 Exhibit 168, # 169 Exhibit 169, # 170 Exhibit 170, # 171 Exhibit 171, # 172 Exhibit 172, # 173 Exhibit 173, # 174 Exhibit 174, # 175 Exhibit 175, # 176 Exhibit 176, # 177 Exhibit 177, # 178 Exhibit 178, # 179 Exhibit 179, # 180 Exhibit 180, # 181 Exhibit 181, # 182 Exhibit 182, # 183 Exhibit 183, # 184 Exhibit 184, # 185 Exhibit 185, # 186 Exhibit 186, # 187 Exhibit 187, # 188 Exhibit 188, # 189 Exhibit 189, # 190 Exhibit 190, # 191 Exhibit 191, # 192 Exhibit 192, # 193 Exhibit 193, # 194 Exhibit 194, # 195 Exhibit 195, # 196 Exhibit 196, # 197 Exhibit 197, # 198 Exhibit 198, # 199 Exhibit 199, # 200 Exhibit 200, # 201 Exhibit 201, # 202 Exhibit 202, # 203 Exhibit 203, # 204 Exhibit 204, # 205 Exhibit 205, # 206 Exhibit 206, # 207 Exhibit 207, # 208 Exhibit 208, # 209 Exhibit 209, # 210 Exhibit 210, # 211 Exhibit 211, # 212 Exhibit 212, # 213 Exhibit 213, # 214 Exhibit 214, # 215 Exhibit 215, # 216 Exhibit 216, # 217 Exhibit 217, # 218 Exhibit 218, # 219 Exhibit 219, # 220 Exhibit 220, # 221 Exhibit 221, # 222 Exhibit 222, # 223 Exhibit 223, # 224 Exhibit 224, # 225 Exhibit 225, # 226 Exhibit 226, # 227 Exhibit 227, # 228 Exhibit 228, # 229 Exhibit 229, # 230 Exhibit 230, # 231 Exhibit 231, # 232 Exhibit 232, # 233 Exhibit 233, # 234 Exhibit 234, # 235 Exhibit 235, # 236 Exhibit 236, # 237 Exhibit 237, # 238 Exhibit 238, # 239 Exhibit 239, # 240 Exhibit 240, # 241 Exhibit 241, # 242 Exhibit 242, # 243 Exhibit 243, # 244 Exhibit 244, # 245 Exhibit 245, # 246 Exhibit 246, # 247 Exhibit 247, # 248 Exhibit 248, # 249 Exhibit 249, # 250 Exhibit 250, # 251 Exhibit 251, # 252 Exhibit 252, # 253 Exhibit 253, # 254 Exhibit 254, # 255 Exhibit 255, # 256 Exhibit 256, # 257 Exhibit 257, # 258 Exhibit 258, # 259 Exhibit 259, # 260 Exhibit 260, # 261 Exhibit 261)(Consovoy, William) (Additional attachment(s) added on 6/18/2018: # 262 Unredacted version of Declaration, # 263 Exhibit 1 (filed under seal), # 264 Exhibit 2 (filed under seal), # 265 Exhibit 5 (filed under seal), # 266 Exhibit 6 (filed under seal), # 267 Exhibit 7 (filed under seal), # 268 Exhibit 8 (filed under seal), # 269 Exhibit 9 (filed under seal), # 270 Exhibit 10 (filed under seal)) (Montes, Mariliz). (Additional attachment(s) added on 6/18/2018: # 271 Exhibit 11 (filed under seal), # 272 Exhibit 12(filed under seal), # 273 Exhibit 13 (filed under seal), # 274 Exhibit 14 (filed under seal), # 275 Exhibit 16 (filed under seal), # 276 Exhibit 17(filed under seal), # 277 Exhibit 18(filed under seal), # 278 Exhibit 19 (filed under seal), # 279 Exhibit 20 (filed under seal), # 280 Exhibit 22 (filed under seal), # 281 Exhibit 23 (filed under seal), # 282 Exhibit 24 (filed under seal), # 283 Exhibit 25(filed under seal), # 284 Exhibit 26 (filed under seal), # 285 Exhibit 28 (filed under seal), # 286 Exhibit 29 (filed under seal), # 287 Exhibit 31 (filed under seal), # 288 Exhibit 32 (filed under seal), # 289 Exhibit 33 (filed under seal), # 290 Exhibit 35 (filed under seal), # 291 Exhibit 36 (filed under seal), # 292 Exhibit 37 (filed under seal), # 293 Exhibit 38(filed under seal), # 294 Exhibit 39 (filed under seal), # 295 Exhibit 40 (filed under seal), # 296 Exhibit 41, # 297 Exhibit 42 (filed under seal), # 298 Exhibit 43 (filed under seal), # 299 Exhibit 44(filed under seal), # 300 Exhibit 45 (filed under seal), # 301 Exhibit 46 (filed under seal), # 302 Exhibit 47 (filed under seal), # 303 Exhibit 48 (filed under seal), # 304 Exhibit 51 (filed under seal)) (Montes, Mariliz).
EXHIBIT 145
PRELIMINARY DRAFT
Admissions Part ll
Subtitle
February 14, 2012
Office of Institutional Research
Highly Confidential - Attorney's Eyes Only
HAP V00065741
7
Summary
PRELIMINARY DRAFT
• Athletes and Legacies explain the difference in raw admit rates for Asian and
White applicants.
• Asian applicants have higher average ratings and test scores (excluding the
personal rating).
• Differences exist in the raw admit rates of Asian and White students with
similar test scores and academic indices. Even top scores and ratings don't
guarantee admission.
• Personal rating is important in models of the admissions process and drive
some of the demographic differences we see.
HARV00065742
Highly Confidential - Attorneys Eyes Only
2
PRELIMINARY DRAFT
Admit Rates by Ethnicity, Classes of2007-2016
18% 0111*
16 _
%
14% -
•
•
•
•
•
12% -
10% -
c
,
s
e-=
`----' Illi' '
•
• .1.• ...
▪ I
‘
'' 't =-,
Nb
,
...4•0 4%.. %
01
/
Asian
'\
4M•1
I
NI
.
ft
% ft NA
11111b
8 _
%
International
Oft,
Min
- African American
— Hispanic
6 %
- — Native American
— Unknown
4 %
W hite
2
%
0
%
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
Admit Rate -White
7
.60%
9.39%
7
.72%
7.71%
8.56%
7.72%
6.57%
6.36%
5.45%
6.02%
Admit Rate -Asian
11.69%
12.13%
11.27%
11.58%
10.94%
9.93%
9.11%
8.76%
7.58%
7.50%
Difference
4
.09%
2.74%
3
.55%
3.88%
2.38%
2.21%
2.54%
2.40%
2.14%
1.48%
HARV00065743
Highly Confidential - Attorney's Eyes Only
3
PRELIMINARY DRAFT
Non-Legacy, Non-Athlete Admit Rates by Ethnicity, Classes of2007-2016
16% 4
•11.
.1
/
1
4
14 _
%
12% •
•
el%
40
0
40
0
10% -
•
4
1M1
•
IMO
1
1
*ma
w
e.
MM.
IMM
•
S
i
• %
r4
4.
8
%
•
•••
6
%
4
10.
- — African American
4.
4
4
▪ 444
.
•••
Asian
4 •
0.
I nternational
414
6
one
- — Hispanic
\
awn
.
411P
— Native American
4
%
— Unknown
W hite
2
%
0
%
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
Admit Rate -White
7
.21%
8.90%
7.34%
7.34%
8.09%
7.21%
6.00%
5.96%
4.93%
5.34%
Admit Rate -Asian
.75%
8
8.79%
8.30%
8.26%
7.46%
7.17%
6.46%
6.25%
5.32%
5.09%
Difference
1.54%
-0.12%
0.96%
0.93%
-0.64%
-0.04%
0.46%
0.29%
0.38%
-0.25%
HARV00065744
Highly Confidential - Attorney's Eyes Only
4
PRELIMINARY DRAFT
Difference in Average Test Scores and Ratingsfor White and Asian Applicants
SAT ll Average
SATAverage
Alumni Rating 2
I
I
Alumni Rating 1
Guidance Rating
I
Teacher Rating 2
Teacher Rating 1
Personal Rating
Extracurricular Rating
Academic Rating
-0.2
-0.1
White Higher
o
0.1
0.2
0.3
0.4
Asian Higher
Notes:
• Excludes legacies and athletes.
• OIR doesn't have all ratings for all years, so number of applicants differs for each rating/test score.
• Differences Vrikc'srenig- liceMSR Only
d
HARV00065745
7
PRELIMINARY DRAFT
7
Admit Rates by Academic Indexfor White and Asian Applicants, Classes of2007-2016
6
,000 -
- 60%
White N
I
4
,000 —
- 50%
White Admit Rate /
/
/ i
• _/
5,000
- 40%
asian(N)
•
white(N)
- 30%
3
,000 —
I
I
/
.. -.
•
/ Asian Admit Rate
Asian N
2
,000 —
/
0
0
••
••
at
,
IMP
010
OM
....
c
o/
MO
INID
,
•••
.N.
.
.....
r
•
60
•••
moms
a
/
=ID
,
es
IP
ammo
6/.
ma.
•
•
0
.•
1.
=Mr
20%
do
10%
awn iiir"
•
•
0
0
%
0
.02
0.12
0.22
0.32
0.42
0.52
0.62
0.72
0.82
0.92
1.02
1.12
1.22
1.32
1.42
1.52
white
— asian
••
0
0
o
sa
.1
••
•
••
••
••
1,000
1.
••
•
•
40
.
.1
1.62
Standardized Academic Index (0 = Average Academic Index)
Notes:
• Excludes legacies and athletes.
• Academic Index doesn't account for everything in admissions process. Even top rated students barely have a 50% adrrlitRV00065746
Highly Confidential - Attorneys Eyes Only
rate.
PRELIMINARY DRAFT
Admit Rates by Average SAT!for White and Asian Applicants, Classes of2007-2016
_ 35%
10,000 -
9
,000
I
- 30%
8
,000
I i
I
1
I
7
,000
6
,000 —
5,000
- 25%
- 20%
—asian(N)
white(N)
I
- 15%
4,000
— — white
— — asian
3
,000 —
10%
2,000
- 5%
1,000
,
40
OUP
MM.
= ...
0
is
6
0
MP
61
or'
ma*
mlEi,
62
0
%
63
64
65
66
67
68
69
Notes:
• Excludes legacies and athletes.
• Spikiness in distribution due to rounding averages to integers.
Highly Confidential - Attorneys Eyes Only
70
71
72
73
74
75
76
77
78
79
80
HARV00065747
7
Model
PRELIMINARY DRAFT
Odds Ratiosfor Main Effect Logistic Model
High Personal Rating
African American
Legacy
Native American
High Extracurricular Rating
Early Applicant
High Academic Rating
Hispanic
z-Academic Index
First Generation
Class of 2008
Class of 2012
Class of 2014
Class of 2013
Class of 2011
Class of 2010
Class of 2009
Class of 2015
Average SAT II
Average SAT I
Unknown
International
Female
Class of 2016
Asian
Other
0
1
2
3
4
5
6
7
8
9
10
HARV00065748
Highly Confidential - Attorneys Eyes Only
73
Model
PRELIMINARY DRAFT
Logit Coefficientsfor Main Effect Logistic Model
High Personal Rating
African American
Legacy
Native American
High Extracurricular Rating
Early Applicant
High Academic Rating
Hispanic
z-Academic Index
First Generation
Class of 2008
Class of 2012
Class of 2014
Class of 2013
Class of 2011
Class of 2010
Class of 2009
Class of 2015
Average SAT II
Average SAT I
Unknown
International
Female
Class of 2016
Asian
Other
-1
-0.5
0
0.5
1
1.5
2
2.5
HARV00065749
Highly Confidential - Attorney's Eyes Only
7
Methods
Goal: Using various admissions ratings, how well can we approximate admit rates by race/ethnicity and the demographic
composition of the admitted students pool?
Strategy:
• Fit a series of basic logistic regression models.
•
Generate fitted probabilities of admissions - given an applicant's characteristics how likely are they to be admitted (01)?
•
For each class, select the 2100 applicants with the highest probability of admissions as our simulated admitted class.
•
Examine resulting demographics and admit rates by ethnicity.
Notes:
• Students with no academic index are excluded from this analysis. N =,admit rate =
Model 1: Academic only
Academic Index
Academic Rating
Model 2: Add legacy and
athlete
Academic Index
Academic Rating
legacy
athlete
Model 3: Add personal and
extracurricular
Academic Index
Academic Rating
legacy
athlete
Personal Rating
Extracurricular Rating
Model 4: Add demographics
Academic Index
Academic Rating
legacy
athlete
Personal Rating
Extracurricular Rating
Gender
Ethnicity
HARV00065750
Highly Confidential - Attorneys Eyes Only
Projected Admitted Student Pools
100% -
=NM
7
%
PRELIMINARY DRAFT
6%
7%
90%
8%
9
%
8
0% 10%
70% Native American
60% Hispanic
•
50% -
International
•
African American
4
0%
Unknown
•
3
0%
•
Asian
51%
44%
2
0%
43%
Actual
White
•
10%
0
%
Model 1
Model 2
Model 3
Model 4
Academics rily
Legacy and Athlete
Extracurricular and
Personal
Demographics
Academics Only
Model 1
43.04%
Asian
African American
I nternational
Hispanic
N ative American
Unknown
White
Legacy and Athlete
Model 2
31.40%
Extracurricular and Personal
Model 3
25.99%
Demographics
Model 4
17.97%
0.67%
7.27%
2.42%
0.21%
8.02%
38.37%
1.83%
5.86%
2.62%
0.32%
2.36%
7.39%
11.12%
Hiytily CUIl1udIitk1I- Attu,'iuy'b Eyeb Only
9.93%
48.03%
4.07%
0.41%
9.14%
50.63%
7.68%
9.83%
1.21%
8.11%
44.08%
Actual
18.66%
10.46%
8.90%
9.46%
1.23%
8.09
%
43.mw00065751
11
Projected Admit Rates
PRELIMINARY DRAFT
2
0% -18%
16%
14%
-II-Asian
12%
MI-African American
10%
I nternational
8
%
•
•
6
%
U-Native American
- -Unknown
4
%
2
%
0
%
Model 1
Model 2
Model 3
Model 4
Academics Only
Legacy and Athlete
Extracurricular and
Personal
Actual
Demographics
Asian
African American
I nternational
Hispanic
N ative American
Unknown
White
Academics Only
Model 1
17.35%
0.75%
5.13%
2.34%
1.97%
9.45%
9.43%
Highly Confidential - Attorneys Eyes Only
Legacy and Athlete
Model 2
12.66%
Extracurricular and Personal
Model 3
Demographics
Model 4
10.48%
7.24%
2.07%
4.14%
2.53%
2.98%
11.70%
11.81%
2.67%
5.22%
3.94%
3.81%
10.77%
12.45%
12.59%
5.42%
9.51%
11.17%
9.56%
10.84%
Actual
7.63%
12.00%
6.37%
9.27%
11.43%
9.67%
itriwyw065752
12
Conclusions
PRELIMINARY DRAFT
HAP V00065753
Highly Confidential - Attorneys Eyes Only
131
Possible Explanations
PRELIMINARY DRAFT
HARV00065754
Highly Confidential - Attorneys Eyes Only
The Personal Rating: Numeric value doesn't capture full picture of applicant
Inputs
PRELIMINARY DRAFT
Outputs
SAT Scores
Reader classifies student
Academic Rating
GPA
Calculation performed
> Academic Index
Alumni Interview
Teacher Ratings
Reader classifies student
Personal Rating
Guidance Counselor Ratings
Application Essay?
Academic Index
SAT Scores +GPA
Accounts for 98% of the variation in Academic Index. Academic
Index is a weighted average.
Academic Rating
SAT Scores +GPA
Personal Rating
School Support +
Alumni Interviews
Accounts for 70% of the variation in Academic Rating. Can't
explain some of the variation because Academic Rating data
doesn't include the granuality provided by +and -. Also
potentially some noise due to readers
Accounts for 20% of the variation in Personal Rating. Inputs of
Teacher Evaluations, Guidance Counselor Evaluations, and
Alumni Interviews don't fully explain how Personal Ratings are
assigned. Don't have any numeric rating of personal statement.
RV00065755
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75
Dockets: Differences in Admit Rates by Region not Explained by Athletes and IegcAeRAFT
Admit Rates by Region for White and Asian Non-Athlete, Non-Legacy Applicants,
C
lasses of2007-2016
Percent Asian
Total Applicants
tr)
CO
8
a
)
CI)
▪
Asian
•
White
•
Midwest and Southwest
1 1
Massachusetts
Northeast and Atlantic
CA and Northwest
-yr
39%
28%
25%
24%
23%
20%
2
0%
20%
42,033
12,165
31,706
22,000
21,373
17,161
31,135
Total
•
15,733
Notes:
• Excludes legacies and athletes.
HARV00065756
Highly Confidential - Attorneys Eyes Only
7.61
Other Possibilities
PRELIMINARY DRAFT
•Information lost by not recording plusses and minuses.
•Yield considered when admitting students?
• Other factors not used in models:
•Children faculty/staff
•Search for socioeconomic diversity
• High school quality/opportunities open to student
• Dockets
HARV00065757
Highly Confidential - Attorneys Eyes Only
17