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

Filing 503

MOTION for Leave to File to Participate as Amici Curiae by Harvard Black Alumni Society, Harvard Asian American Alumni Alliance, Association of Black Harvard Women, 21 Colorful Crimson. (Attachments: # 1 Exhibit Declaration, # 2 Exhibit Declaration, # 3 Exhibit Declaration, # 4 Exhibit Declaration)(Thayer, Kenneth)

EXHIBIT 1

UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF MASSACHUSETTS
BOSTON DIVISION

STUDENTS FOR FAIR ADMISSIONS, INC,
Plaintiff,
v.
Civil Action No. 1:14-cv-14176-ADB

PRESIDENT AND FELLOWS OF
HARVARD COLLEGE (HARVARD
CORPORATION),
Defendant.

DECLARATION OF JAMES MATHEW
(21 COLORFUL CRIMSON)
James Mathew, pursuant to 28 U.S.C. Section 1746, declares the following:
1.

My name is James Mathew. I am a member of the Harvard College Class of 2021.

2.

I am the co-founder and President of 21 Colorful Crimson (“21CC”) and am

submitting this Declaration individually and on behalf of 21CC in support of the continued
utilization of race-consciousness admissions practices at Harvard College.
3.

21CC was founded in January of 2018 to unite artists from diverse backgrounds

through musical collaboration. After witnessing several impromptu musical gatherings among
students, I realized that the Harvard community could benefit from a structured artistic
collaboration space that brings together a diverse group of singers to connect over their shared love
of music, especially at a time when much of our nation was facing extreme division.

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4.

While the organization operates as a creative incubator, with members creating,

recording, and performing original music, 21CC also seeks to break down racial, ethnic, and social
divisions at Harvard through art.
5.

21CC operates under three pillars: creativity, inclusion, and love. Through

application of these three pillars, 21CC aims to employ art to defy stereotypes, advocate for
diversity, overcome the social divisions within the community, and celebrate the multifaceted
talents of students at Harvard. In the future, 21CC hopes to expand the ways in which it promotes
this mission by organizing campus-wide campaigns and conversations about diversity.
6.

The members who comprise 21CC come from a range of backgrounds and

represent a variety of racial and ethnic, socioeconomic, cultural, and geographic identities. The
diversity of 21CC is integral to the development of our performances, in which we showcase pieces
that are a fusion of many genres and styles.
7.

21CC supports the consideration of race in the admissions process at Harvard

because there is immense value in creating a diverse student body. Throughout the coverage of
this lawsuit, Harvard students’ experiences and opinions have been given little consideration, but
we have a first-hand understanding of the value of a diverse class. 21CC determined it was
imperative to share how diversity of Harvard was a vital component of our college experience and
central to the formation of our organization.
8.

21CC realizes that the educational experience at Harvard is not merely limited to

course curriculum. The opportunity to engage with peers who come from diverse backgrounds and
who hold diverse perspectives has been central to our members’ intellectual experiences. This
engagement has been a critical part of my Harvard experience, and I feel that I have grown from
these discussions and the ability to share my lived experiences with classmates. Diversity is key

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to this experience. If students are surrounded by those who have a similar story to them, they miss
out on enriching dialogue. There is an immeasurable educational benefit in students being provided
the opportunity to trade perspectives, confront biases, and learn from each other’s experiences.
9.

Being a member of a diverse class at Harvard has also allowed me to engage with

all facets of my identity and personality. As an Indian American student, I grew up in a white,
racially homogenous neighborhood, where I was often an isolated face of color. Because of my
race, my peers would often ascribe stereotypes to me. They would cast me as a “bookworm” or
someone whose entire identity was defined by academic achievement. As a result of this
stereotyping, I felt pigeon-holed as a specific type of person and unable to express all the parts of
my personality.
10.

When I came to Harvard, I was able to meet other Asian American students who

had similar experiences and feelings of isolation. I also witnessed many students of color defying
the stereotypes I had faced growing up by striving for academic excellence while also being
engaged with activities outside of the classroom, for example, as poets, athletes, musicians, and
activists. This inspired me to create spaces, such as 21CC, where everyone was free to engage with
all parts of their identity. At Harvard, I no longer feel an obligation to behave in a way that
conforms to stereotypes about Asian American students. Instead, through 21CC, I can express the
creative, artistic sides of my personality, defying the labels I felt trapped by during high school.
11.

21CC is also enriched by the interactions it fosters between members from different

backgrounds. In speaking with Olivia Owens, co-founder and Director of Operations of 21CC, I
learned about her own experience as a Black woman growing up in a white, racially homogenous
community. She told me that in her hometown in Vermont, she was often the lone person of color
in her community. Similar to my experience, she was subjected to many explicit and implicit

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stereotypes by her peers. In school settings, she was often met with assumptions about her
intelligence. Her peers assumed that she was not smart and that she was unable to excel
academically. As a result of being on the receiving end of this vitriol, she told me that she often
doubted her own capabilities and intellect.
12.

However, once she arrived at Harvard, she found a community that helped her step

into her full self. Being around other people of color who were navigating the same academic and
social environment allowed her to realize her own potential. Finding a community of people who
were challenging the stereotypes society had previously ascribed them gave her the confidence to
reject the low expectations her peers had placed on her, and instead excel both inside and outside
the classroom.
13.

In addition to understanding the benefits of a diverse class, 21CC recognizes that

applicants to Harvard should not be reduced to their test scores. Harvard’s admissions policies
consider the whole experience of a student and the variety of ways in which they could contribute
to the community. 21CC, in particular, benefits from members who are creative, collaborative, and
community oriented, traits that are not measured by standardized tests. In solely emphasizing test
scores, Students for Fair Admissions reduces Asian American to “model minorities,” which
reinforces harmful stereotypes about their breadth of interests, talents, and personalities.
Furthermore, this lawsuit continues to perpetuate the harmful notion that Asian American students
are a monolith. Even amongst Asian American students, there is great diversity that often goes
unrecognized to the detriment of students, and maintaining diversity at Harvard encourages
diversity of Asian American representation, with students of varying Asian ethnicities, traditions,
and personalities.

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14.

While we are frustrated by the possibility that Harvard admissions officers may

have been biased against Asian American applicants, we do not believe that the proper solution is
the elimination of race-conscious admissions. Rather, training, policies, and procedures should be
put in place to deal with the alleged bias at issue. The answer is not to ignore racial identity but to
combat racial bias.
15.

21CC believes that in targeting race-conscious admission policies, this lawsuit

seeks to pit minority groups against one another. We recognize, however, that all students benefit
from a diverse campus. We see this benefit in the work of 21CC each day.
16.

If Harvard were to eliminate race-conscious admissions, we believe students would

be harmed by the loss of diversity. Students would lose out on the intellectual and emotional
relationships that are formed from engaging with individuals from various backgrounds.
Additionally, our campus is home to prominent student organizations that contribute to Harvard’s
culture in meaningful ways. Eliminating race-conscious admissions would negatively impact the
membership of cultural groups and affinity organizations, including 21CC, and the critical role
they play in shaping, as well as challenging, campus culture.

I declare under penalty of perjury that the foregoing is true and correct.
Executed on this day, August 27, 2018.

/s/ James Mathew
James Mathew

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