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Affirmative action has been the subject of numerous court cases, and has been questioned upon its constitutional legitimacy. In 2003, a Supreme Court decision regarding affirmative action in higher education ("Grutter v. Bollinger", 539 US 244 – Supreme Court 2003) permitted educational institutions to consider race as a factor when admitting students. Alternatively, some colleges use financial criteria to attract racial groups that have typically been under-represented and typically have lower living conditions. Some states such as California (California Civil Rights Initiative), Michigan (Michigan Civil Rights Initiative), and Washington (Initiative 200) have passed constitutional amendments banning public institutions, including public schools, from practicing affirmative action within their respective states. Conservative activists have alleged that colleges quietly use illegal quotas to discriminate against people of Asian, Jewish, and Caucasian backgrounds and have launched numerous lawsuits to stop them.