In 2003, the United States Supreme Court affirmed the importance of diversity in legal education when it decided Grutter v. Bollinger.' Underlying the Court's decision was the recognition that a diverse student body benefits the education of all law students, which in turn, impacts society in important ways. While recognition of educational diversity as a compelling state interest allows law schools to consider race in admissions, race-based admissions policies alone cannot address the truly compelling state interest underlying educational diversity: training lawyers to practice in a multicultural society, including effectively representing clients from different racial, ethnic, and socioeconomic backgrounds. Law schools must do more than simply attempt to create diverse classrooms. Law schools must implement cross-cultural education to teach law students the skills necessary to understand cultural differences and to effectively communicate with clients and colleagues whose cultural backgrounds differ from their own.

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