A class-action lawsuit has been filed against the University of California, Los Angeles’ David Geffen School of Medicine, accusing it of unlawfully implementing race-based admissions policies. This legal action represents white and Asian students who claim they were rejected from the school.

In a 38-page complaint filed Thursday, plaintiffs take on UCLA’s of admissions dean, who in 2020, adopted an “Anti-Racism Roadmap” to create a “path toward racial justice, equity, diversity and inclusion.”

“Consistent with its racial goals, Geffen made Jennifer Lucero dean of admissions in 2020,” said the complaint. “Lucero is an outspoken advocate for using race to make admission and hiring decisions in medical schools and hospitals.”

The lawsuit alleges that “[u]nder the guise of ‘holistic’ review,” Lucero and her “handpicked committee members routinely and openly discuss race (and racial proxies) and use race as a factor to make admission decisions. Lucero berates and belittles committee members who raise concerns about admitting minority students because of their race despite low GPAs and MCAT scores.”

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According to the complaint, UCLA Medical School uses race as a decisive factor in making admissions decisions, even superseding GPA and MCAT scores.

The federal lawsuit, jointly filed by Do No Harm (DNH), an advocacy organization founded in 2022 to protect health care from what it describes as “woke discrimination,” and Students for Fair Admissions, the group that successfully litigated to end affirmative action programs in college admissions. The plaintiffs are represented by law firm Consovoy McCarthy PLLC, named for the late William Consovoy who represented Donald Trump in the battle over releasing tax returns with former Manhattan District Attorney Cy Vance.

UCLA’s policies amount to illegal “racial balancing” in contravention of the Supreme Court’s 2022 decision in the case Students for Fair Admissions v. Harvard, as well as California’s Proposition 209, which prohibits discrimination in public employment, public education, and public contracts, passed in 1996.

Per the complaint:

This much is clear: UCLA’s illegal racial discrimination has harmed and is continuing to harm applicants, including Plaintiffs and their members. In this race based system, all applicants are deprived of their right to equal treatment and the opportunity to pursue their lifelong dream of becoming a doctor because of utterly arbitrary criteria. Plaintiffs are entitled to relief.

Further, the plaintiffs said that, “Lucero and the Admissions Committee routinely admit black applicants with below-average GPA and MCAT scores — even significantly below-average scores — while requiring whites and Asians to have near-perfect scores to even be seriously considered,” all while explicitly discussing race during the application process.

As if to underscore this point, the complaint quotes Lucero deliberating with the committee about a Black applicant saying, “Did you not know African American women are dying at a higher rate than everyone else? We need people like this in the medical school.”

According to the filing, “Committee members report that the bar for underrepresented minorities is ‘as low as you could possibly imagine,”” and that the committee “completely disregards grades and achievements” for minority applicants.

Further, plaintiffs said, “Lucero regularly bullies and berates members of the Admissions Committee who voice concerns about admitting below-average black applicants by labeling them as ‘privileged’ and implying that they are racist.”

Lucero also allegedly had committee members “sit through a two-hour lecture on Native American history taught by [her] sister” after Lucero allegedly “berated” members for rejecting a Native American applicant.

The plaintiffs raise equal protection violations under the 14th Amendment as well as civil rights violations under California state law, and argue that UCLA’s admissions practices cannot survive strict scrutiny.

“Whistleblowers confirm that the admissions committee, either led or intimidated by Lucero, use all available methods to glean an applicant’s race, openly discuss applicants’ race, and use race to hold students to different standards based on race,” the lawsuit also says.

The Trump administration’s Department of Health and Human Services (HHS) announced in March that UCLA’s medical school is under investigation for “giv[ing] unlawful preference to applicants based on their race, color, or national origin” in contravention of President Donald Trump’s Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, which directed federal agencies to end diversity, equity, and inclusion initiatives and programs.

On May 6, HHS issued a “Dear Colleague” letter prohibiting medical schools from “relying on race-based criteria, racial stereotypes, and facially neutral criteria that operates as a pretext for race” in admissions decisions.

HHS Office for Civil Rights Acting Director Anthony Archeval defended the move, saying that it “protects students and patients by ensuring health care providers, and those in the health professions pipeline, are selected based on merit and clinical skills, not race.”

In a statement, DNH chairman Stanley Goldfarb said the organization was “fighting for all the students who have been racially discriminated against by UCLA under the guise of political progress. All medical schools must abide by the law of the land and prioritize merit, not immutable characteristics, in admissions.”

Representatives for the parties did not respond to request for comment.

You can read the full complaint here.