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 4

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 MADISON TRICE
(ASSOCIATION OF BLACK HARVARD WOMEN)
Madison Trice, pursuant to 28 U.S.C. Section 1746, declares the following:
1.

My name is Madison Trice. I am a member of the Harvard College Class of 2021.

2.

I am the Political Action Chair of the Association of Black Harvard Women

(“ABHW”) and am submitting this Declaration individually and on behalf of ABHW in support
of the continued utilization of race-conscious admissions practices at Harvard College.
3.

ABHW was founded in 1975 when students from Radcliffe College met to develop

an organization that would allow Black women to remain united after graduation. Since its
inception, ABHW has focused on cultivating a place and community for Black Harvard women
both on campus, and in the world at large.
4.

ABHW seeks to bring Black women together for academic, cultural, political and

social purposes. Members combine their intellect, spirit, and resources to address the needs and
problems of Black women both at Harvard College and within the University as a whole. ABHW

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also engages in discourse about national and international women’s issues and causes. In addition
to social and community events, ABHW provides opportunities for professional advancement,
mentorship, political action, and community service. Each of these activities is centered around
the goal of creating a space of belonging and sisterhood for Black women on campus.
5.

While we feel privileged to be students at Harvard, there are many challenges to

being a Black woman on this campus. It is our devotion to Black women and Black social causes
that has compelled us to contribute our voices and experiences to this discussion. Having
experienced the privilege of being a student within a diverse class at Harvard, we believe it is our
responsibility to make sure these same opportunities are extended to our sisters, and all students,
who will come after us.
6.

Whereas Black women were historically some of the last individuals to be admitted

to Harvard, ABHW is concerned that Black women would be some of the first to suffer if raceconscious admission practices were eliminated. Moreover, we are worried about the ramifications
this decision would have not just at Harvard College, but on Black women applicants at universities
nationwide.
7.

ABHW supports Harvard’s ability to consider race as one of many factors in

admission because we have witnessed and personally reaped the benefits of a diverse educational
environment. Our academic experiences at Harvard have been enriched by the opportunity to learn
from our classmates who come from a variety of racial, socioeconomic, and geographic
backgrounds. Their contributions during class and lectures provide us with a more robust
understanding of our world.
8.

Diverse student voices enrich classroom discussion and also add to the academic

contributions that come out of Harvard. Each year our peers develop novel theses that are informed

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by and borne out of their own background and experiences. For example, I knew a student from
New York who wrote their thesis on urban life and litefeet, a dance style that emerged in the Bronx.
It is unlikely that other students, who were not exposed to this dance tradition in their neighborhood
growing up, would have considered such a topic.
9.

Diversity at Harvard does not merely influence academic spaces—it truly impacts

all elements of campus life. From athletics to spirituality, the diversity of students enables each
scene and component of Harvard life to be richer and more vibrant. ABHW members have been
given a front row seat to the ways in which diversity can enrich the mission and work of a student
organization. During our board meetings, we have seen how students from different backgrounds
may recognize unique needs that are not being addressed on campus. Drawing from their unique
vantage point, our members have proposed mentorship programs for individuals interested in
STEM fields, or recommended specific speakers that could provide commentary on an under
discussed area of student development. The diversity of our membership has not just resulted in
novel ideas, but has created opportunities for students to collaborate on projects aimed at
improving the Harvard community.
10.

Despite the strides Harvard has made to address diversity, ABHW recognizes that

there are still institutional shortcomings which can cause students to feel a sense of isolation. In
many ways, Harvard can still feel like a space reserved for students who are white and wealthy.
However, we have seen how the diversity of students can counteract this notion of exclusivity by
providing students with a sense of community. Race-conscious admissions has allowed for a
diverse class of students who are able to carve out spaces for students who previously have not felt
a sense of belonging in the historically dominant culture of Harvard.

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11.

ABHW also recognizes that persistent racism and structural inequities in this

country still preclude many individuals from accessing higher education. Race-conscious
admissions play a part in addressing the inequality of opportunity that has historically excluded
people of color from academic communities.
12.

As a member of a diverse class at Harvard, I have experienced immense personal

growth and development by and through this community. This growth is further highlighted when
I contrast it with my previous educational experience at my private high school in Houston, Texas.
My sense of belonging at my white, racially homogenous high school was precarious at best, and
non-existent at worse. There were a number of times during my high school experience where I
was subjected to implicit and explicit racism. During several of our football games, students
arrived to the stands in black face. At times, academic opportunities were denied to me on account
of my race. While my high school had a Black affinity group, which provided me some semblance
of a community, it still remained difficult for me to fully talk about my experiences since we
represented such a small percentage of the student body. These feelings of isolation were
compounded by the fact that minority groups at my high school could not meet with each other
and share in a sense of solidarity.
13.

Once I arrived at Harvard, through ABHW and other communities, I was able to

find a sense of belonging that I did not have during high school. While at times I still face racism
and other forms of oppression, I have a robust community that helps me confront and address these
challenges. In many ways, Harvard has been a space of healing for me. These communities, and
the friendships I have developed within them, have provided me with space to discuss strategies
for how to navigate the challenges of a particular institution, learn from the experiences of my
peers, and celebrate my heritage and racial identity. This personal growth has also been enriched

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by inter-community dialogue and collaboration. While cultural affinity groups at my high school
mostly operated in isolation, the intergroup solidarity I have experienced and witnessed at Harvard
has broadened my perspective. My experience at Harvard has been a welcome contrast to my high
school experience, and I would hope the opportunity to experience such a vibrant community
would be preserved for future students.
14.

If Harvard were to eliminate race-conscious admissions, we believe that the

University would lose out on students who could make meaningful contributions, academic or
otherwise, to the campus. It is impossible to measure merit without taking into consideration an
individual’s whole experience. For many students, their race is a critical part of their development
and identity.
15.

A student body crafted solely based on applicants’ grades and standardized test

scores would be incomplete. There are many individuals at Harvard who are defined by much
more than a perfect score on a standardized test. The richness of my class comes from students
who are talented musicians, or those who are passionate about eradicating homelessness. The
multitude of diverse talents and passions that students possess cannot be adequately captured by
the narrow definition of merit advanced by Students for Fair Admissions in this case.
16.

In addition to hurting Harvard as a whole, the elimination of race-conscious

admissions would have cognizable harms for ABHW. When I arrived on campus for orientation,
a Black undergraduate student began to cry as she told us she was grateful to see the next
generation of Black women arrive on campus. It would be devastating to watch our board members
graduate and not see those spaces replenished by incoming students who can carry out ABHW’s
legacy. The future of our organization and its place at Harvard is undoubtedly called into question
by this case.

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17.

ABHW believes that Harvard’s admissions policies are not without fault. It is

important for Harvard to consider their assessment of students who come from a variety of
disadvantaged backgrounds. For instance, there could be more attention and support provided to
low-income students and first-generation college students. As an institution, Harvard must do
better when developing policies and procedures to address the needs of all students.
18.

Despite shortcomings, eliminating race-conscious admissions would not solve any

of the inadequacies in Harvard’s process. ABHW believes that any effort to eradicate raceconscious admissions would only serve to further burden marginalized students and hurt the
Harvard community as a whole.

I declare under penalty of perjury that the foregoing is true and correct.
Executed on this day, August 29, 2018.

/s/ Madison Trice
Madison Trice

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