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involving the University of Michigan. In Grutter v. Bollinger, the court ruled that race can be
               considered among other factors in the admissions process, while in Gratz v. Bollinger it
               ruled out affirmative action plans that seemed to set a strict numerical goal for minority
               admissions.26 Partly as a response to the rulings, Michigan voters in November 2006
               backed a referendum banning affirmative action in public education, contracting, and
               employment. Clearly, this will not be the final word on the issue. Given the contentious
               nature of race-based admissions programs, it is likely that affirmative action will come
               before the courts again in the relatively near future.


               African Americans and American Politics



               The example of Senator Barack Obama of Illinois illustrates both the impressive gains that
               African Americans have made in American political life and the limits of their acceptance as
               full participants. Although he is relatively young and is serving only his first term in the
               Senate, Obama has emerged as one of the most popular and sought-after figures in the
               Democratic Party, as well as a serious contender for his party’s presidential nomination in
               2008. At the same time, Obama is the only black member of the 100-seat Senate and only
               the third black senator in modern history. Likewise, only two African Americans have won
               election to a governorship: Douglas Wilder of Virginia in 1990 and Deval Patrick of
               Massachusetts in 2006.


               There are a number of factors behind the difficulty blacks have encountered in winning
               statewide elections where the electorate is mostly white. Lingering prejudice may be part
               of the answer. Another factor is the ghettoized nature of black politics. While literally
               thousands of blacks have won election to the U.S. House of Representatives, city councils,
               and state legislatures, most represent districts in which black voters predominate, often by
               overwhelming margins. Black legislators are thus often perceived, fairly or not, as focused
               on the needs of blacks and favoring an agenda that is well to the left of the political
               mainstream. In the 109th Congress, there were 43 members of the Congressional Black
               Caucus, all of whom were Democrats and almost all of whom represented districts where
               minorities predominated.27
               To a modest degree, the number of majority black districts has remained high due to the
               policy of racial gerrymandering, under which legislative districts are drawn so as to ensure
               that the majority of voters are black, or in some cases Hispanic. In some states, blacks’
               desire to ensure that certain congressional districts would remain secure for black
               candidates has led to the anomalous situation of African American Democrats joining with
               Republicans in the drawing of neighboring districts that would likely produce Republican
               victories. The Supreme Court has ruled against several of the more extreme racially drawn
               districts while allowing race or ethnicity to be taken into consideration in a modest way in
               other cases.


               In the future, of course, the indicator of America’s success at assimilating minorities into
               the political system will be the participation and representation of the entire constellation
               of nonwhite groups, and not just blacks. Although the Republican Party has long been
               accused of hostility to minority interests, the administration of President George W. Bush

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