Supreme Court to Revisit Issue of Race as Factor in Higher Education Admissions

Supreme Court to Revisit Issue of Race as Factor in Higher Education Admissions

Neal H. Hutchens
University of Kentucky

The permissibility of race-conscious admissions policies in higher education has once again taken legal center stage, with the U.S. Supreme Court having accepted Fisher v. University of Texas at Austin (2011) for review. In Fisher, the Supreme Court will consider arguments that a law guaranteeing acceptance to a Texas university for students graduating in the top 10% of their high school class negates the need for using race in any admissions decisions at the University of Texas at Austin. Previously, in Grutter v. Bollinger (2003), the Supreme Court upheld a race-conscious admissions program at the University of Michigan School of Law. In this case, the Court held that the law school could consider race, along with many other factors, in seeking to attain the educational benefits that come from having a diverse student body.

Grutter was greeted by supporters of affirmative action in higher education as a legal victory. But the legal standards approved in the case now face an uncertain future. Having accepted Fisher for review, the Supreme Court again appears poised to consider the extent to which a public college or university may rely on race in admissions. Grutter was decided five to four by a sharply divided Court. Changes in the Supreme Court’s membership since the Grutter case have resulted in uncertainty regarding the extent to which the legal standards announced in the decision will remain intact.

A noteworthy change to the Supreme Court is the departure of Justice Sandra Day O’Connor, author of the majority opinion in Grutter and a key swing vote in the case. Since assuming Justice O’Connor’s seat, Justice Samuel Alito has joined opinions disfavoring governmental reliance on racial classifications. Some Supreme Court observers believe enough votes now exist to overturn or substantially restrict the use of race in admissions approved of in Grutter (Carey, 2012; Liptak, 2012). A probable supporter of the university’s policies, Justice Elena Kagan, has also decided not to take part in the decision, likely because of her previous involvement with the Fisher litigation while serving as the Solicitor General of the United States. Put simply, the mix of key decision-makers on the current Supreme Court presents questions regarding future legal limitations on affirmative action.

Overview of Fisher v. University of Texas at Austin

In Fisher v. University of Texas at Austin, white, Texas residents not selected for admission to the university argue that the institution should not be able to use race as a factor in admissions decisions. The applicants contend that the university should be precluded from including race in any admissions decisions because of the success of a legislatively mandated plan, the Top Ten Percent Law, which assures Texas students graduating in the top 10% of their high school class admission into a public university in the state. The rejected applicants argue that implementation of the plan has resulted in sufficient enrollment of underrepresented student populations to negate the consideration of race by the university in admissions decisions not made under the Top Ten plan. Both a federal trial court and the U.S. Court of Appeals for the Fifth Circuit ruled in favor of the university. The courts held that the challenged admissions practices represented an appropriate consideration of race in institutional efforts to enhance student diversity in alignment with the legal framework approved of in Grutter.

The standards challenged in Fisher applied to only a limited percentage of admissions decisions by the university. As noted in the Fifth Circuit’s opinion, the overwhelming majority of slots were filled using the Top Ten plan, accounting for 81% of the overall slots awarded for the 2008 entering class and for 88% of the seats allotted to Texas residents. Accordingly, the vast majority of Texas residents admitted to the university were accepted through the Top Ten plan.

For admissions decisions for Texas residents not made using the percentage plan, race constituted one of multiple factors that could be considered in an application. For this group of applicants, the university calculated a Personal Achievement Index (PAI), which was based on three scores. Two of the scores were based on evaluation of an applicant’s essays. The third score—the personal achievement score—was given slightly greater weight than the other two scores; it was determined by holistic consideration of an applicant’s achievements, experiences, and background. As part of the personal achievement score, evaluators could consider a “special circumstances” element that could reflect “the socioeconomic status of the applicant and his or her high school, the applicant’s family status and family responsibilities, the applicant’s standardized test score compared to the average of her high school, and—beginning in 2004—the applicant’s race” (Fisher, 2011, p. 228).

In considering the admissions practices at issue, the Fifth Circuit pointed out that the university was not relying on some type of quota system, which would not pass legal scrutiny. The court explained that no single factor in admissions decisions, including race, was considered on a separate basis from other criteria or given any kind of specific numeric value. Instead, evaluators considered all factors in a holistic manner, with each application given individualized consideration. The court observed that, if constituting a factor at all in a particular admissions decision, “race ha[d] the potential to influence only a small part of the applicant’s overall admissions score” (Fisher, 2011, p. 228).

The applicants challenging the university’s admissions procedures have argued that the success of the Top Ten Percent Law provided a race-neutral alternative that negated the need for the university to consider race in any of its admissions decisions. The university has countered with studies demonstrating that reliance on the percentage plan alone failed to result in the enrollment of a critical mass of underrepresented students and left many courses with very few to no underrepresented students enrolled.

In challenging the university’s admissions practices that permitted consideration of race, the denied applicants looked to support from a post-Grutter Supreme Court case involving firefighters where the Court rejected a city’s invalidation of a test used for promotions (Ricci v. DeStafano, 2009). The Fifth Circuit responded in Fisher that the Supreme Court had not retreated from the standards announced in Grutter regarding the use of race as a permissible factor in admissions by public colleges and universities.

Grutter v. Bollinger and Permissibility of Race as Factor in Admissions

In Grutter v. Bollinger (2003), a five to four decision, the Supreme Court held that public higher education institutions are permitted to consider race as one of multiple factors in admissions in order to realize the educational benefits of diversity. The case involved an applicant to the University of Michigan School of Law who challenged the school’s admission policy, which considered race as one of many possible admissions factors. The law school’s criteria required admissions officials to provide individualized consideration to each application. While undergraduate grades and standardized test scores constituted important factors for consideration, the law school policy did not guarantee or reject particular applications solely on these standards. Instead, the admissions policy considered a number of other criteria that would contribute to an entering class’ diversity, including in relation to race and ethnicity.

Five justices in Grutter concluded that the law school’s admissions system was constitutional. In a companion case, Gratz v. Bollinger (2003), the Supreme Court invalidated an undergraduate admissions program at the University of Michigan, declaring that it did not provide individualized consideration of applicants’ files and mechanically included race as a factor in admissions.

Justice O’Connor, writing the majority opinion in Grutter, began her analysis by noting that governmental classifications relying on race are subject to strict scrutiny, a rigorous standard of legal review. Under this standard, the use of race in admissions had to be narrowly tailored to further a compelling governmental interest. The opinion stressed that all governmental classifications, even those seeking to benefit minority populations, are subject to strict scrutiny.

A majority of justices in Grutter accepted the argument that the law school’s use of race in admissions to obtain the educational benefits of diversity constituted a compelling governmental interest. In accepting this position, the Court adopted the diversity rationale advanced by Justice Lewis Powell in Bakke v. Regents of the University of California (1978) that had failed to garner the support of a majority of justices. In approving of the educational benefits of diversity as constituting a compelling governmental interest, the Court in Grutter also noted the special deference that has been shown by courts to colleges and universities in the context of educational matters.

Having accepted that the educational benefits of diversity constituted a compelling governmental interest, the Supreme Court in Grutter also held that the law school’s use of race was narrowly tailored. The opinion discussed that race comprised only one of many possible factors considered in admissions decisions in relation to assembling a diverse class. Applicants’ files also received individualized, holistic evaluation. The majority deemed it relevant as well that, while seeking to enroll a critical mass of underrepresented students in pursuit of the educational benefits of diversity, the law school did not rely on any kind of strict percentages that would constitute a quota system.

Post-Grutter School Assignment Cases

The Supreme Court revisited the issue of using race in admissions in a pair of consolidated cases decided post-Grutter that involved school assignment plans at the elementary and secondary education levels (Parents Involved in Community Schools v. Seattle School District No. 1, 2007). The cases dealt with challenges to student assignment plans voluntarily adopted by school districts in Seattle, Washington, and Louisville, Kentucky. In both cases, a majority of the court rejected the legal permissibility of the plans.

Chief Justice John Robert’s opinion for the majority in Parents Involved stated that in Grutter the Supreme Court emphasized that each student received individualized consideration. The majority in Parents Involved determined that the school assignment plans under consideration failed to give this same kind of individualized consideration. Near the conclusion of his opinion in Parents Involved announcing the Court’s judgment, Chief Justice Roberts, arguing against the permissibility of the school assignment plans, stated that “[t]he way to stop discrimination on the basis of race is to stop discriminating on the basis of race” (Parents Involved, 2009, p. 748). While his opinion noted that Grutter involved special concerns related to higher education, the Parents Involved decision indicates that a current majority of the Court may greet any race conscious programs with heavy skepticism.

Supreme Court’s Review of Fisher Leaves Grutter Standards in Doubt

The Supreme Court’s decision to review the Fisher case means that Grutter’s legal legacy may prove relatively brief. Accordingly, what can be viewed as the rather limited use of race in higher education admissions permitted in Grutter now faces an uncertain future. Fisher may mark the end point of a judicial pattern in recent decades characterized by an overall resistance to allowing race as a legally permissible factor in higher education admissions to serve social justice and equality goals.

As noted, the majority in Grutter looked approvingly to Justice Powell’s opinion in Regents of the University of California v. Bakke (1978) that advocated the educational benefits of diversity as a permissible reason to include race in admissions. A dissenting opinion in Bakke by Justice William Brennan and joined by three other justices shows a constitutional road not taken in relation to the use of race in higher education admissions. In this opinion, Justice Brennan argued for more lenient judicial review of racial classifications under certain circumstances. He argued that, rather than the highest level of judicial scrutiny (strict scrutiny), the kind of admissions program at issue in Bakke should have been subjected to intermediate scrutiny. His opinion contended that courts should distinguish between governmental racial classifications meant to benefit racial minorities and to address a legacy of racism in the United States versus classifications that sought to discriminate against racial minorities.

Justice Brennan’s argument that governmental uses of race meant to benefit minority groups should receive an intermediate level of judicial scrutiny did not prevail. In a series of cases, the Supreme Court eventually determined that all racial classifications should be subject to strict scrutiny. Furthermore, the Supreme Court made it clear that in seeking to remedy past and ongoing discrimination, a racial classification had to be aimed at redressing specific acts or instances of discrimination rather than seeking to address general societal discrimination. Accordingly, Grutter was decided in the context of previous decisions that had already greatly restricted instances when the government could use race to benefit minority groups.

Moses and Chang (2006) discuss how an emphasis on the “diversity rationale” in higher education, including in judicial decisions, has “weakened the justification for race-conscious admissions based on corrective or distributive justice” (p. 9). As they point out, while “broader justice concerns” are not completely distinct from the diversity rationale, such an “interest appears at best to be indirect” (Moses & Chang, 2006, p. 9). Moses and Chang’s concern with an overemphasis on the diversity rationale highlights how, from one perspective, the Grutter decision marked a rather modest and somewhat narrow legal approval of the use of race in public higher education admissions. Now, with the Supreme Court set to review Fisher v. University of Texas at Austin, even the continued legal permissibility of this limited use of race in public higher education admissions appears in doubt.

Discussion Questions

  • Does your institution use race-conscious admissions policies of the kind authorized in the Grutter decision? If so, what would be the impact on admissions at your college or university resulting from a Supreme Court ruling that prohibits or restricts such race-conscious policies?
  • Does your state or university have race neutral admissions policies that are intended to achieve greater diversity in admissions? What effect do these policies have on your admissions outcomes?
  • How does your college or university interpret the concept of “critical mass?” What kinds of data collection initiatives are used to evaluate your institution’s degree of success in achieving a “critical mass” of students from underrepresented populations?

References

Carey, K. (2012, March 4). Commentary: Justice and equity are on the line in ‘Fisher v. Texas.’ The Chronicle of Higher Education.

Fisher v. University of Texas at Austin, 631 F.3d 213 (5th Cir. 2011), cert. granted, 2012 WL 538328 (Feb. 21, 2012).

Gratz v. Bollinger, 539 U.S. 244 (2003).

Grutter v. Bollinger, 539 U.S. 306 (2003).

Liptak, A. (2012, February 7). Justices take up race as a factor in college entry. The New York Times. Retrieved from http://www.nytimes.com

Moses, M.S., & Chang, M.J. (2006). Toward a deeper understanding of the diversity rationale. Educational Researcher, 35(1), 6-11.

Parents Involved in Community Schools v. Seattle School District No. 1, 551 U.S. 701 (2007).

Regents of the University of California v. Bakke, 438 U.S 265 (1978).

Ricci v. DeStafano, 129 S. Ct. 2658 (2009).

About the Author

Neal H. Hutchens is an assistant professor in the Department of Educational Policy Studies and Evaluation at the University of Kentucky. His research focuses on legal issues arising in higher education.

Please e-mail inquiries to Neal H. Hutchens.

Disclaimer

The ideas expressed in this article are not necessarily those of the Developments editorial board or those of ACPA members or the ACPA Governing Board, Leadership, or International Office Staff.

837 thoughts on “Supreme Court to Revisit Issue of Race as Factor in Higher Education Admissions”

  1. เดี๋ยวนี้ผู้คนต่างมองหาหนทางการสร้างรายได้ที่ลงทุนน้อย UFABET คาสิโนออนไลน์ได้เก็บทุกเกมออนไลน์ที่ท่านชอบใจไม่ว่าจะเป็นบาคาร่า พนันบอล สล็อต ยิงปลา รวมทั้งเกมใหม่ๆที่พึ่งพิงเปิดตัวไปสู่แวดวงเกมออนไลน์ UFABET จ่ายจริง จ่ายไว ไม่มีขั้นต่ะ

  2. I do not even know how I ended up right here, however I believed this post was once good. I do not recognise who you are but definitely you are going to a well-known blogger when you aren’t already 😉 Cheers!

  3. This very blog is definitely cool and diverting. I have chosen many interesting advices out of it. I ad love to come back every once in a while. Thanks a bunch!

  4. Your style is very unique compared to other folks I have read stuff from.I appreciate you for posting when you have the opportunity, Guess I willjust book mark this blog.

  5. Aw, this was an extremely nice post. Spending some time and actual effort to generate a top notch articleÖ but what can I sayÖ I hesitate a whole lot and never seem to get nearly anything done.

  6. An interesting discussion is definitely worth comment. I think that you should publish more about this issue, it may not be a taboo subject but usually people don’t discuss such subjects. To the next! Kind regards!!

  7. Thank you, I’ve just been looking for info approximately this topic for a while and yours is the greatest I’ve discovered till now. However, what concerning the conclusion? Are you positive concerning the source?

  8. I am not sure where you are getting your info, but great topic.I needs to spend some time learning much more or understanding more.Thanks for excellent info I was looking for this information formy mission.

  9. Very good information. Lucky me I discovered your blog by accident (stumbleupon). I’ve book marked it for later!

  10. ที่สุดของเกมที่ให้ความบันเทิงสูงสุดเต็มอิ่มด้วยเอฟเฟคสุดเลิศทำเงินเร็วมอบเงินไว คงจะหนีไม่พ้นสล็อตออนไลน์ ที่เหล่านักเล่นการพนันชูให้เป็นยอดเยี่ยมของเกมออนไลน์ UFABET แหล่งรวมเกมออนไลน์ก็ไม่พลาดที่จะจัดสล็อตออนไลน์มาให้สมาชิกอย่างจุใจ

  11. Do you have a spam issue on this blog; I also am a blogger, and I was wondering your situation; wehave created some nice methods and we are looking to exchange techniques with others, be sure to shoot me an email if interested.

  12. Good day! I could have sworn I’ve been to this blog before but after reading through some of the post I realized it’snew to me. Anyways, I’m definitely glad I found it and I’ll be book-marking and checking back frequently!

  13. Hello, you used to write magnificent, but the last few posts have been kinda boring¡K I miss your tremendous writings. Past several posts are just a little bit out of track! come on!

  14. พนันบอลออนไลน์ที่คอบอลไม่สมควรพลาด มาแปลงความพอใจเป็นรายได้กันนะครับ UFABET เปิดให้คุณแทางบอลออนไลน์ได้อย่างง่ายดายมีทุกแบบที่คุณรู้สึกชื่นชอบไม่เพียงเท่านั้นยังมีเกมออนไลน์นานาประการอย่างเช่น บาคาร่า สล็อต ยิงปลาแล้วก็เกมสมาชิกใหม่ก็มีมากเลยขอรับ

  15. Hi there, just became alert to your blog through Google, and found that it’s trulyinformative. I am going to watch out for brussels.I’ll appreciate if you continue this in future. Lots of people will be benefited from your writing.Cheers!

  16. What’s Going down i’m new to this, I stumbled upon this I’ve discovered It absolutely useful and it has aided me out loads. I am hoping to contribute & assist other customers like its aided me. Good job.

  17. An interesting discussion is definitely worth comment. There’s no doubt that that you should write more about this subject matter, it might not be a taboo matter but usually folks don’t talk about such issues. To the next! Many thanks!!

  18. Hi my friend! I want to say that this article is amazing,nice written and come with approximately allimportant infos. I’d like to peer more posts like this .

  19. You can certainly see your skills within the article you write.The sector hopes for even more passionate writers such as youwho aren’t afraid to say how they believe. At all times go after your heart.

  20. Hello! Do you know if they make any plugins to help with SEO?I’m trying to get my blog to rank for some targeted keywords but I’m not seeing very good results.If you know of any please share. Kudos!

  21. Hi i am kavin, its my first occasion to commentinganyplace, when i read this piece of writing i thought i could also create comment due tothis sensible article.

  22. I blog quite often and I genuinely thank you for your content. The article has truly peaked my interest. I will bookmark your blog and keep checking for new information about once per week. I opted in for your Feed too.

  23. ??? ??? ???? ?????? ?? ????? ????? ????? ?? ?????? ?????? ????? . ????? ??????? ????? ?????? ????? ??????? ?????? ??????? ???? ????? ?????? ??????? ??? ?????? ??? ?? ??????? money ????? ????????.

  24. Your article gave me a lot of inspiration, I hope you can explain your point of view in more detail, because I have some doubts, thank you. 20bet

  25. Hello! I could have sworn Iíve been to this blog before but after browsing through some of the articles I realized itís new to me. Nonetheless, Iím certainly happy I found it and Iíll be bookmarking it and checking back regularly!

  26. Aw, this was a really nice post. Taking the time and actual effort to make asuperb article… but what can I say… I procrastinate a lot and don’t manage toget anything done.

  27. Do you have a spam issue on this blog; I also am a blogger, and I was curious about your situation; many of us have created some nice procedures and we are looking to trade techniques with other folks, why not shoot me an email if interested.

  28. Hi there, just became aware of your blog through Google, and found that it is really informative. IЎ¦m gonna watch out for brussels. IЎ¦ll appreciate if you continue this in future. A lot of people will be benefited from your writing. Cheers!

  29. Howdy! Would you mind if I share your blog with my twitter group? There’s a lot of people that I think would really appreciate your content. Please let me know. Many thanks

  30. This is a very good tip particularly to those fresh to the blogosphere. Simple but very accurate informationÖ Thanks for sharing this one. A must read article!

  31. สมัครSLOTXO เว็บสล็อต SLOTXOTHSLOTXO สมัครสมาชิก ฝาก-ถอนด้วยระบบออโต้ รวดเร็วทำรายการเสร็จภายใน 30 วินาทีสมัครสมาชิกslotxo

  32. Do you have a spam issue on this blog; I also am a blogger, and I was curious about your situation; we have developed some nice practicesand we are looking to exchange strategies with others, be sure to shoot me an emailif interested.

  33. Hello There. I found your blog using msn. This isa really well written article. I will be sure to bookmark it and come backto read more of your useful information. Thanks for the post.I will definitely return.

  34. Hola! I’ve been following your blog for a long time now and finally gotthe bravery to go ahead and give you a shout out from Austin Texas!Just wanted to tell you keep up the greatjob!

  35. I will right away snatch your rss as I can’tto find your email subscription link or e-newsletter service.Do you have any? Kindly permit me recognize in orderthat I may subscribe. Thanks.

  36. Wow that was odd. I just wrote an very long comment but after I clicked submit my comment didn’t show up. Grrrr… well I’m not writing all that over again. Anyway, just wanted to say fantastic blog!

  37. I used to be recommended this blog by my cousin. I’m nolonger sure whether this submit is written via him as nobody else know such distinct about my trouble.You are incredible! Thank you!

  38. Thanks for ones marvelous posting! I genuinely enjoyed reading it, you’re a great author. I will be sure to bookmark your blog and will often come back from now on. I want to encourage one to continue your great job, have a nice evening!

  39. There are some interesting points in time in this article but I don’t know if I see all of them center to heart. There is some validity but I will take hold opinion until I look into it further. Good article , thanks and we want more! Added to FeedBurner as well…

  40. Normally I don’t read post on blogs, but I would like to say that this write-up very compelled me to check out and do so! Your writing style has been amazed me. Thanks, very great article.

  41. What’s Taking place i’m new to this, I stumbled upon this I’ve foundIt absolutely useful and it has helped me out loads.I’m hoping to give a contribution & help different users like its helped me.Good job.

  42. Thanks , I’ve recently been searching for information approximately thistopic for ages and yours is the best I have found outso far. But, what concerning the bottom line? Are you certain about thesupply?

  43. Aw, this was an incredibly good post. Taking the time and actualeffort to create a very good article… but what can I say…I hesitate a lot and don’t seem to get nearly anythingdone.

  44. No matter if some one searches for his necessary thing, so he/she desires to be available that in detail, therefore that thing is maintained over here.

  45. Hello, its fastidious paragraph on the topic of mediaprint, we all understand media is a impressive source of data.Review my blog post – pussy888apk (returnorbit.net)

  46. I wanted to thank you for this good read!! I certainly enjoyed every bit of it. I’ve got you saved as a favorite to check out new stuff you post…

  47. Prior to you decide to create your own checklist to include an idea associated with what camping checklist ought to. Really … A listing can be greater than what you need.

  48. Heya i’m for the first time here. I came across this board and I findIt really useful & it helped me out much. I hope to give something back and aid otherslike you aided me.

  49. I don’t even know the way I finished up here, but I assumed this submit was once great. I do not recognise who you are however definitely you’re going to a well-known blogger if you aren’t already 😉 Cheers!

  50. Great post. I was checking continuously this blog and I am impressed!Very helpful info particularly the last part 🙂I care for such information a lot. I was seeking this particular information for a very long time.Thank you and good luck.

  51. Aw, this was an extremely nice post. Spending some time and actual effort to generate a good articleÖ but what can I sayÖ I put things off a lot and never manage to get nearly anything done.

  52. Nice post. I was checking continuously this blog and I am impressed! Very helpful info specially the last part 🙂 I care for such information much. I was seeking this particular info for a long time. Thank you and good luck.

  53. Pretty nice post. I just stumbled upon your blog and wanted tomention that I’ve truly enjoyed browsing your blog posts.After all I will be subscribing for your rss feed and I hopeyou write again very soon!

  54. I just like the helpful info you provide on your articles. I’ll bookmark your blog and check once more right here regularly. I’m moderately sure I’ll be informed plenty of new stuff proper here! Best of luck for the next!

  55. What’s up i am kavin, its my first time to commenting anywhere,when i read this article i thought i could also create comment dueto this sensible article.

  56. I am curious to find out what blog system you are utilizing?I’m having some small security issues with my latest blog and I’d like to find something more safe.Do you have any recommendations?

  57. I blog quite often and I really appreciate your information. Your article has really peaked my interest. I am going to bookmark your blog and keep checking for new information about once per week. I subscribed to your RSS feed too.

  58. Pretty nice post. I just stumbled upon your blog and wanted to say that I have truly enjoyed browsing your blog posts. In any case I’ll be subscribing to your rss feed and I hope you write again very soon!

  59. Xoilac Tv Thẳng đá Bóng keo nha cai hom nayĐội tuyển nước Việt Nam chỉ cần một kết quả hòa có bàn thắng nhằm lần loại hai góp mặt tại World Cup futsal. Nhưng, nhằm thực hiện được điều này

  60. I’m really impressed with your writing talentsand also with the format on your blog. Is that this a paid topicor did you customize it yourself? Anyway keep up the excellent highquality writing, it is rare to see a nice blog like this onenowadays..

  61. You can certainly see your expertise within the workyou write. The world hopes for even more passionate writers such asyou who are not afraid to say how they believe. All the time go after your heart.

  62. I like the valuable info you provide in your articles. I’ll bookmark your blog and check again here frequently. I am quite sure I’ll learn many new stuff right here! Good luck for the next!

  63. Very nice post. I just stumbled upon your blog and wished to say that I’ve trulyenjoyed browsing your blog posts. After allI will be subscribing to your rss feed and I hope you write again very soon!

  64. Hi there just wanted to give you a brief heads up and let you know a few of thepictures aren’t loading correctly. I’m not sure why but I think its alinking issue. I’ve tried it in two different browsers and both show the same outcome.

  65. I just like the helpful information you supply in your articles. I will bookmark your blog and check once more right here frequently. I’m reasonably certain I will be informed a lot of new stuff proper right here! Good luck for the following!

  66. Thanks on your marvelous posting! I certainly enjoyed reading it, youcould be a great author. I will always bookmark your blog and will come back someday.I want to encourage you to ultimately continue your great writing, have a nice evening!

  67. I do trust all the concepts you have offered for your post. They’re very convincing and will certainly work. Still, the posts are very quick for beginners. May you please extend them a little from next time? Thank you for the post.

  68. I am extremely impressed with your writing skills as well as with the layout on your blog. Is this a paid theme or did you customize it yourself? Either way keep up the excellent quality writing, it?s rare to see a great blog like this one today..

  69. I am not sure where you’re getting your info, but good topic.I needs to spend some time learning more or understanding more.Thanks for great info I was looking for this info for my mission.

  70. I’m a housewife hydrea side effects message boards Clinicians should assess heart attack patients, particularly women, for anxiety and depression so that timely treatment can be started,” Prof Serpytis said.

  71. 📍ของดีไม่พูดเยอะ✅โปรโมชั่น เพียบ เกมส์เยอะ💥สูตรฟรี ไม่มีอั้น💸✨แจก ขนาดนี้ เปิดตัวน้องใหม่💨🌟สายตรง บริการดีเยี่ยม ไม่เทลูกค้า

  72. magnificent points altogether, you simply gained a new reader.What could you recommend in regards to your submit that you made a few days ago?Any positive?Look at my blog post asmr but

  73. A motivating discussion is definitely worth comment. I do think that you need to write more about this subject, it may not be a taboo subject but usually people don’t discuss these subjects. To the next! Cheers.

  74. What’s Taking place i’m new to this, I stumbled upon this I have discovered It absolutely usefuland it has aided me out loads. I am hoping to contribute & help different customers like itsaided me. Good job.

  75. Aw, this was a really good post. Finding the time and actual effort to create a superb articleÖ but what can I sayÖ I procrastinate a whole lot and never manage to get anything done.

  76. ว่ากันว่าเงินอยู่ในอากาศอยู่ที่ว่าใครจะหาวิธีเอามาได้ “การพนันออนไลน์”เป็นหนึ่งช่องทางที่สามารถจับเงินในอากาศได้ ด้วยเงินลงทุนที่ต่ำแต่สามารถทำกำไรได้สูงแบบไรข้อจำกัดจึงเป็นสาเหตุที่ดึงดูดนักพนันออนไลน์ให้หลั่งไหลเข้ามาที่ คาสิโนออนไลน์ แห่งนี้

  77. Hey There. I found your blog the use of msn. This is an extremely smartly written article. I’ll make sure to bookmark it and return to learn more of your useful information. Thank you for the post. I’ll definitely comeback.

  78. I really like your article. It’s evident that you have a lot knowledge on this topic. Your points are well made and relatable. Thanks for writing engaging and interesting material.

  79. You could certainly see your expertise within the article you write.The arena hopes for more passionate writers such as you who aren’t afraid to mention how they believe.Always follow your heart.

  80. I blog quite often and I genuinely appreciate your information. The article has really peaked my interest. I am going to take a note of your blog and keep checking for new details about once per week. I subscribed to your RSS feed as well.

  81. Howdy! I just want to give you a huge thumbs up for your great information you’ve got right here on this post. I’ll be returning to your blog for more soon.

  82. Hmm is anyone else having problems with the pictures on thisblog loading? I’m trying to figure out if its a problemon my end or if it’s the blog. Any feedback would be greatlyappreciated.

  83. Thanks for the marvelous posting! I truly enjoyed reading it, you’re a great author.Iwill make certain to bookmark your blog and may come back in the future.I want to encourage one to continue your great writing, havea nice morning!

  84. You completed various good points there. I did a search on the subject matter and found the majority of persons will consent with your blog.

  85. I really like your writing style, excellent info, regards for putting up :D. “Your central self is totally untouched By grief, confusion, desperation.” by Vernon Howard.

  86. What’s Going down i am new to this, I stumbled upon this I have found It absolutely helpful and it has helped meout loads. I am hoping to contribute & assist different customers like itshelped me. Great job.

  87. It’s actually a great and useful piece of info. I am gladthat you simply shared this helpful information with us.Please stay us informed like this. Thank you for sharing.

  88. Excellent post. I was checking constantly this blog and I am impressed! Very helpful info specifically the last part 🙂 I care for such information much. I was looking for this certain info for a long time. Thank you and best of luck.

  89. Hi there! This post could not be written any better! Reading through this post reminds me of my good old room mate! He always kept talking about this. I will forward this article to him. Pretty sure he will have a good read. Thank you for sharing!

  90. I don’t like pubs finasteride online uk The gains also suggest investors are becoming morecomfortable with the prospect of the Federal Reserve slowing thepace of its economic stimulus, which has been a major driver ofthe equity rally this year.

  91. hi!,I love your writing very a lot! share we keep up a correspondence extra about your article on AOL?I require an expert in this house to unravel my problem.Maybe that is you! Looking forward to see you.

  92. Hi! I’ve been reading your blog for some time now and finally got the courage to go ahead and give you a shout out from Kingwood Texas! Just wanted to mention keep up the great job!

  93. I blog often and I really appreciate your information. The article has really peaked my interest. I’m going to bookmark your blog and keep checking for new details about once a week. I subscribed to your RSS feed too.

  94. Greɑt post howeve Ι was wanting to ҝnoԝ if ʏoucoukd write a litte morе on this topic? I’d be vеry thankful if yօu coulɗelaborate a little Ьit furtһer. Bless you!My blog post – slot online

  95. Using EMF Blocker products from Vortex BioShield® gives you peace of mind when it comes to fighting off EMF radiation and keeping your body and mind healthy.

  96. An intriguing discussion is worth comment. I believe that you should publish more about this issue, it might not be a taboo matter but generally people don’t speak about these topics. To the next! Many thanks!!

  97. I am now not certain the place you are getting your information,however great topic. I needs to spend a while findingout much more or figuring out more. Thank youfor excellent information I was searchingfor this information for my mission.

  98. Do you have a spam problem on this blog; I also am ablogger, and I was curious about your situation; many of us have developed some nice methodsand we are looking to trade techniques with others, please shoot me an email if interested.

  99. Have you ever heard of second life (sl for short). It is essentially a online game where you can do anything you want. SL is literally my second life (pun intended lol). If you want to see more you can see these Second Life articles and blogs

  100. Hey There. I found your blog using msn. This is an extremely well written article.I’ll make sure to bookmark it and return to read more ofyour useful info. Thanks for the post. I will definitely comeback.

  101. Neotonics is an essential probiotic supplement that works to support the microbiome in the gut and also works as an anti-aging formula. The formula targets the cause of the aging of the skin.

  102. I haven’t checked in here for a while since I thought it was getting boring, but the last few posts are great quality so I guess I’ll add you back to my everyday bloglist. You deserve it my friend 🙂

  103. Dentitox Pro is a liquid dietary solution created as a serum to support healthy gums and teeth. Dentitox Pro formula is made in the best natural way with unique, powerful botanical ingredients that can support healthy teeth.

  104. Gorilla Flow is a non-toxic supplement that was developed by experts to boost prostate health for men. It’s a blend of all-natural nutrients, including Pumpkin Seed Extract Stinging Nettle Extract, Gorilla Cherry and Saw Palmetto, Boron, and Lycopene.

  105. ProDentim is a nutritional dental health supplement that is formulated to reverse serious dental issues and to help maintain good dental health.

  106. BioFit is an all-natural supplement that is known to enhance and balance good bacteria in the gut area. To lose weight, you need to have a balanced hormones and body processes. Many times, people struggle with weight loss because their gut health has issues.

  107. FitSpresso stands out as a remarkable dietary supplement designed to facilitate effective weight loss. Its unique blend incorporates a selection of natural elements including green tea extract, milk thistle, and other components with presumed weight loss benefits.

  108. Kerassentials are natural skin care products with ingredients such as vitamins and plants that help support good health and prevent the appearance of aging skin. They’re also 100% natural and safe to use. The manufacturer states that the product has no negative side effects and is safe to take on a daily basis.

  109. Boostaro increases blood flow to the reproductive organs, leading to stronger and more vibrant erections. It provides a powerful boost that can make you feel like you’ve unlocked the secret to firm erections

  110. GlucoTrust is a revolutionary blood sugar support solution that eliminates the underlying causes of type 2 diabetes and associated health risks.

  111. EyeFortin is a natural vision support formula crafted with a blend of plant-based compounds and essential minerals. It aims to enhance vision clarity, focus, and moisture balance.

  112. Erec Prime is a cutting-edge male enhancement formula with high quality raw ingredients designed to enhance erection quality and duration, providing increased stamina and a heightened libido.

  113. Puravive introduced an innovative approach to weight loss and management that set it apart from other supplements. It enhances the production and storage of brown fat in the body, a stark contrast to the unhealthy white fat that contributes to obesity.

  114. Prostadine is a dietary supplement meticulously formulated to support prostate health, enhance bladder function, and promote overall urinary system well-being. Crafted from a blend of entirely natural ingredients, Prostadine draws upon a recent groundbreaking discovery by Harvard scientists.

  115. The Quietum Plus supplement promotes healthy ears, enables clearer hearing, and combats tinnitus by utilizing only the purest natural ingredients. Supplements are widely used for various reasons, including boosting energy, lowering blood pressure, and boosting metabolism.

  116. t’s Time To Say Goodbye To All Your Bedroom Troubles And Enjoy The Ultimate Satisfaction And Give Her The Leg-shaking Orgasms. The Endopeak Is Your True Partner To Build Those Monster Powers In Your Manhood You Ever Craved For..

  117. TerraCalm is an antifungal mineral clay that may support the health of your toenails. It is for those who struggle with brittle, weak, and discoloured nails. It has a unique blend of natural ingredients that may work to nourish and strengthen your toenails.

  118. With its all-natural ingredients and impressive results, Aizen Power supplement is quickly becoming a popular choice for anyone looking for an effective solution for improve sexual health with this revolutionary treatment.

  119. SynoGut is an all-natural dietary supplement that is designed to support the health of your digestive system, keeping you energized and active.

  120. Neurodrine is a fantastic dietary supplement that protects your mind and improves memory performance. It can help you improve your focus and concentration.

  121. Glucofort Blood Sugar Support is an all-natural dietary formula that works to support healthy blood sugar levels. It also supports glucose metabolism. According to the manufacturer, this supplement can help users keep their blood sugar levels healthy and within a normal range with herbs, vitamins, plant extracts, and other natural ingredients.

  122. Amiclear is a dietary supplement designed to support healthy blood sugar levels and assist with glucose metabolism. It contains eight proprietary blends of ingredients that have been clinically proven to be effective.

  123. HoneyBurn is a 100% natural honey mixture formula that can support both your digestive health and fat-burning mechanism. Since it is formulated using 11 natural plant ingredients, it is clinically proven to be safe and free of toxins, chemicals, or additives.

  124. TropiSlim is a unique dietary supplement designed to address specific health concerns, primarily focusing on weight management and related issues in women, particularly those over the age of 40.

  125. Herpagreens is a dietary supplement formulated to combat symptoms of herpes by providing the body with high levels of super antioxidants, vitamins

  126. GlucoCare is a natural and safe supplement for blood sugar support and weight management. It fixes your metabolism and detoxifies your body.

  127. Introducing FlowForce Max, a solution designed with a single purpose: to provide men with an affordable and safe way to address BPH and other prostate concerns. Unlike many costly supplements or those with risky stimulants, we’ve crafted FlowForce Max with your well-being in mind. Don’t compromise your health or budget – choose FlowForce Max for effective prostate support today!

  128. Nervogen Pro, A Cutting-Edge Supplement Dedicated To Enhancing Nerve Health And Providing Natural Relief From Discomfort. Our Mission Is To Empower You To Lead A Life Free From The Limitations Of Nerve-Related Challenges. With A Focus On Premium Ingredients And Scientific Expertise.

  129. Claritox Pro™ is a natural dietary supplement that is formulated to support brain health and promote a healthy balance system to prevent dizziness, risk injuries, and disability. This formulation is made using naturally sourced and effective ingredients that are mixed in the right way and in the right amounts to deliver effective results.

  130. InchaGrow is an advanced male enhancement supplement. Discover the natural way to boost your sexual health. Increase desire, improve erections, and experience more intense orgasms.

  131. My family members all the time say that I am wasting my time here at net,but I know I am getting knowledge every day by reading such good articles or reviews.

  132. Serolean a revolutionary weight loss supplement, zeroes in on serotonin—the key neurotransmitter governing mood, appetite, and fat storage.

  133. When I initially commented I clicked the “Notify me when new comments are added”checkbox and now each time a comment is added I getseveral emails with the same comment. Is there any way you can remove me from that service?Cheers!

  134. Elevate your vitality with Alpha Tonic – the natural solution to supercharge your testosterone levels. When you follow our guidance, experience improved physical performance

  135. Thank you, I have recently been looking for information approximately this topic for a long time and yours is the best I have found out so far. But, what concerning the bottom line? Are you positive concerning the supply?

  136. Asking questions are truly nice thing if you are not understanding something entirely, except this articleoffers fastidious understanding yet.

  137. Aw, this was an incredibly good post. Finding the time and actual effort to create a top notch articleÖ but what can I sayÖ I hesitate a lot and never seem to get anything done.

  138. I like the helpful info you provide in your articles. I will bookmark your blog and check again here regularly. I’m quite certain I will learn many new stuff right here! Best of luck for the next!nkoa 13/09/2021

  139. Normally I do not learn article on blogs, but I would like to say that this write-up very forced me to check out and do so! Your writing style has been amazed me. Thank you, very nice post.

  140. Hi! This is kind of off topic but I need some guidance from an established blog. Is it difficult to set up your own blog? I�m not very techincal but I can figure things out pretty quick.

  141. Heya i am for the first time here. I came across this board and I in finding It really helpful & it helped me out a lot. I hope to provide one thing back and help others like you aided me.

  142. Greetings! This is my first visit to your blog! We are a team of volunteers andstarting a new project in a community in the same niche.Your blog provided us valuable information to work on. You have done a marvellousjob!

  143. Heya i am for the first time here. I came across this board andI find It really useful & it helped me out a lot. I hope to give something back and help others likeyou aided me.

  144. Another year albuterol nebulizer LONDON, Oct 15 (Reuters) – Fund managers are trading moreassets on private exchanges known as dark pools, a growing trendthat clashes with regulators’ mission to improve financialmarket transparency.

  145. Heya! I’m at work browsing your bloog from my new iphone 3gs!Just wanted too say I lovbe reading your blog and look forward to all your posts!Carry on thee excellent work!

  146. Hello there! I could have sworn I’ve been to this blogbefore but after browsing through a few of the articles I realizedit’s new to me. Anyways, I’m certainly delighted I came across it and I’ll be bookmarking itand checking back often!

  147. I’m not sure where you’re getting your info, but good topic.I needs to spend some time learning much more or understanding more.Thanks for great information I was looking for this information for my mission.

  148. Hello there, just became alert to your blog through Google, and found that it’s truly informative.I am going to watch out for brussels. I will be grateful if you continue this in future.Numerous people will be benefited from your writing. Cheers!

  149. A motivating discussion is worth comment. I do believe that you ought to write more on this subject matter, it may not be a taboo subject but generally people don’t speak about these topics. To the next! Kind regards!!

  150. I enjoy what you guys tend to be up too. This sort of clever work and exposure! Keep up the superb works guys I’ve incorporated you guys to my own blogroll.

  151. I’ll right away clutch your rss as I can’t find your email subscription link or e-newsletter service. Do you have any? Please allow me realize so that I may subscribe. Thanks.

  152. Aw, this was a really nice post. In idea I would like to put in writing like this moreover – taking time and precise effort to make an excellent article… however what can I say… I procrastinate alot and certainly not appear to get something done.

  153. Nice post. I was checking continuously this blog and I am impressed!Extremely helpful info specially the last part 🙂 I care for such info much.I was looking for this certain information for a long time.Thank you and good luck.

  154. Vetar na motociklu je magija slobode.

    Aftermarket motorcycle spare parts offer a cost-effective alternative.

    Respectfully challenge opinions to diversify the conversation.

  155. What’s up, this weekend is fastidious in favor of me, for the reason that this time i am reading this wonderful educational piece of writing here at my home.

  156. Aw, this was an incredibly good post. Taking a few minutes and actual effort to make a very good articleÖ but what can I sayÖ I hesitate a lot and don’t seem to get nearly anything done.

  157. I am now not positive the place you’re getting your info, but great topic. I needs to spend a while studying more or working out more. Thank you for wonderful information I was looking for this information for my mission.

  158. A fascinating discussion is worth comment. There’s no doubt that that you ought to publish more about this subject matter, it might not be a taboo subject but generally people don’t discuss these issues. To the next! Many thanks!!

  159. Hi! I just wanted to ask if you ever have any trouble with hackers?My last blog (wordpress) was hacked and I ended up losing several weeks of hard work due to no data backup.Do you have any methods to prevent hackers?

  160. That is a good tip especially to those new to the blogosphere.Short but very precise information… Appreciate your sharing this one.A must read article!

  161. You could definitely see your skills within the paintings you write. The arena hopes for more passionate writers such as you who are not afraid to say how they believe. All the time go after your heart.

  162. Aw, this was a very nice post. Taking a few minutes and actual effort to create a superb article?but what can I say? I put things off a whole lot and don’t manage to get nearly anything done.my blog haojiafu.net

  163. Heya! I’m at work browsing your blog from my new iphone! Just wanted to say I love reading your blog and look forward to all your posts! Carry on the excellent work!

  164. I’m truly enjoying the design and layout of your blog. It’s a very easy on the eyes which makes it much more enjoyable for me to come here and visit more often. Did you hire out a developer to create your theme? Great work!

  165. Heya i am for the first time here. I found this board and I in finding It really useful & it helped me out a lot. I hope to provide something again and aid others like you aided me.

  166. hi!,I love your writing so a lot! percentage we communicate more about your article on AOL? I need an expert on this house to solve my problem. Maybe that’s you! Taking a look ahead to peer you.

  167. Thanks, I have just been looking for information approximately this topic for a while and yours is the best I have came upon so far. However, what in regards to the conclusion? Are you certain in regards to the supply?

  168. Hello! I know this is kinda off topic but Iwas wondering if you knew where I could locatea captcha plugin for my comment form? I’m using the same blog platform as yours and I’m having difficulty finding one?Thanks a lot!

  169. When some one searches for his essential thing, therefore he/she needs to be available that in detail, therefore that thingis maintained over here.

  170. Hi there, just was alert to your blog via Google, and found that it’s really informative. I’m gonna be careful for brussels. I will be grateful if you happen to continue this in future. A lot of people shall be benefited from your writing. Cheers!

  171. Aw, this was an extremely good post. Finding the time and actual effort to produce a very good articleÖ but what can I sayÖ I hesitate a whole lot and don’t manage to get nearly anything done.

  172. I really like what you guys are usually up too. This sort of clever work and reporting!Keep up the wonderful works guys I’ve included you guys to my blogroll.

  173. I¡¦m now not sure where you’re getting your information, however good topic. I must spend a while finding out more or figuring out more. Thanks for excellent info I used to be on the lookout for this info for my mission.

  174. Thank you, I have recently been searching for info about this topic for ages and yours is the greatest I’ve discovered till now. But, what about the bottom line? Are you sure about the source?

  175. hosting deals[…]Wonderful story, reckoned we could combine some unrelated information, nonetheless really worth taking a look, whoa did 1 master about Mid East has got a lot more problerms as well […]

  176. Really it is very useful post and that i choose to read these techniques and in addition I will be having a go and many thanks sharing such kind of techniques please ensure that it stays sharing.Kevin Galstyan md

  177. Hi! I know this is somewhat off topic but I was wondering if you knew where I could find a captchaplugin for my comment form? I’m using the same blog platform as yoursand I’m having difficulty finding one? Thanks a lot!

  178. Usually I don’t read article on blogs, but I would like to say that thiswrite-up very pressured me to check out and do it!Your writing style has been surprised me. Thanks, quite nice post.

  179. araba güneşlik Lilith Pemberton araba göstergeleri Niam May araba gaz yemiyor Esme-Rose Kavanagh araba gösterge işaretleri Elmer Butt araba garajı Ciaran Wong araba gif Selina O’Neill araba gen Chantal Booker araba galerisi Skyla Hess

  180. It is in point of fact a great and helpful piece of info.I am satisfied that you just shared this useful information with us.Please stay us informed like this. Thank you for sharing.

  181. Howdy! This post could not be written much better! Going through this article reminds me of my previous roommate! He continually kept talking about this. I’ll forward this article to him. Pretty sure he’ll have a good read. Thanks for sharing!

  182. It’s really a cool and useful piece of info. I’m glad that you shared this helpful information with us. Please stay us up to date like this. Thanks for sharing.

  183. Hey there! This post couldn’t be written any better!Reading this post reminds me of my good old room mate!He always kept talking about this. I will forward this articleto him. Pretty sure he will have a good read.Thanks for sharing!

  184. I have to thank you for the efforts you have put in penning this blog. I really hope to check out the same high-grade blog posts by you in the future as well. In fact, your creative writing abilities has encouraged me to get my very own blog now 😉

  185. Hi there! Do you know if they make any plugins to assist with SEO?I’m trying to get my blog to rank for some targeted keywords but I’m not seeing very good success.If you know of any please share. Kudos!

  186. Oh my goodness! Awesome article dude! Thanks, However I am experiencing troubles with your RSS. I donít know why I can’t join it. Is there anybody else getting the same RSS issues? Anyone that knows the answer will you kindly respond? Thanks!!

  187. I blog quite often and I seriously appreciate your content. This great article has truly peaked my interest. I’m going to bookmark your blog and keep checking for new information about once per week. I subscribed to your RSS feed too.

  188. 🎲 คาสิโuสด ชั้uนำระดับโลก📲สมัครง่าย ฝาก ถอนโอนไว✔️สมัครขั้นต่ำ 1 บาท🧭แอดมินบริการ 24 ชม.​

  189. Hello there! Do you know if they make any plugins to protectagainst hackers? I’m kinda paranoid about losing everythingI’ve worked hard on. Any tips?

  190. I really like what you guys are up too. This kind of clever work and exposure!Keep up the very good works guys I’ve added you guys toblogroll.

  191. Oh my goodness! an amazing article dude. Thanks However I’m experiencing situation with ur rss . Don’t know why Unable to subscribe to it. Is there anyone getting identical rss problem? Anyone who knows kindly respond. Thnkx

  192. Generally I don’t read post on blogs, however I wish to saythat this write-up very forced me to check out and do so!Your writing taste has been surprised me. Thank you, quite nice article.

  193. Oh my goodness! an outstanding article man. Thank you However I am experiencing concern with ur rss. Don?t know why Not able to subscribe to it. Is there any person getting the same rss trouble? Anybody that understands kindly respond. Thnkx

  194. I’m truly enjoying the design and layout of your blog.It’s a very easy on the eyes which makes it much moreenjoyable for me to come here and visit more often. Did you hire outa developer to create your theme? Superb work!

  195. At this time it sounds like BlogEngine is the top blogging platform out there rightnow. (from what I’ve read) Is that what you’re using on your blog?

  196. I don’t accept as true with this particular blog post. Nonetheless, I did searched with Google and I’ve found out that you’re correct and I seemed to be thinking in the wrong way. Carry on publishing top quality articles like this.

  197. КОМУНАРСЬКИЙ РАЙОННИЙ СУД МІСТА ЗАПОРІЖЖЯКРИНИЧАНСКИЙ РАЙОННЫЙ СУД ДНЕПРОПЕТРОВСКОЙ ОВЛАСТИ

  198. I am not sure where you’re getting your information, but good topic. I needs to spend some time learning more or understanding more. Thanks for fantastic info I was looking for this info for my mission.

  199. Whats rough now is how the programmed look to ones life is not changed. This may sound confusing? It’s almost as if we blitz through our lives with blinders on, not accepting the true meaning of our own existence.

  200. I will immediately seize your rss as I can not in finding your e-mail subscription hyperlink or e-newsletter service. Do you have any? Please allow me know so that I may just subscribe. Thanks.

Leave a Reply

Your email address will not be published. Required fields are marked *