Summary of United States v. Commonwealth of Virginia, District Court (1991)

Facts: Virginia ran a military style education institution called VMI. VMI was higly prestigious but it was only open to male students. United States claimed that the fact that VMI was single-sex violated many female students’ equal protection rights. VMI, on the other hand, claimed that its single-sex institution brings diversity in Virginia’s education system.

Issue: Does VMI’s practice of excluding women from admissions violate Equal Protection Clause?

Holding: No

Legal Reasoning: The court used Mississippi University of Women v. Hogan, a Supreme Court case where intermediate scrutiny was applied, to decide that intermediate scrutiny should also apply to the current case. The court further considered evidence indicating the benefits of single-sex education institutions and VMI’s militaristic education environment to decide that forcing VMI to admit women will dramatically alter its teaching environment and other features which distinguish VMI from other institutions. So the court ruled that “VMI’s single-sex status and its distinctive educational method represent legitimate contributions to diversity in the Virginia higher education system, and that excluding women is substantially related to this mission.”