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            For example, athletes, children of alumni, California residents, and low-income students are a few of the categories of students that benefit from affirmative action considerations in education. The origins of affirmative action are intricately linked to discrimination in the United States. The following is a brief outline of this history. 1940s: President Roosevelt signed an order making discrimination illegal in defense contracting. 1954: The U.S. Supreme Court ruled in Brown v. Board of Education that "separate but equal" facilities on the basis of race were unconstitutionally discriminatory. 1964: Congress passed the Civil Rights Act of 1964 prohibiting discrimination based on race, sex, national origin and religion in employment and education. 1965: President Lyndon Johnson signed an executive order requiring federal contractors to undertake affirmative action to increase the number of minorities they employed. 1969: Department of Labor hearings exposed continued widespread racial discrimination in the construction agency. In response, President Richard Nixon developed the concept of using "goals and timetables" to measure the progress federal construction companies were making in increasing the number of minorities on their payrolls. 1970: President Nixon extended the use of goals and timetables to all federal contractors. 1974: President Nixon declared that affirmative action programs should also include women. 1978: The U.S. Supreme Court held in Regents of California v. Bakke that universities may take race into consideration as a factor in admissions when seeking to accomplish diversity in the student body. The court in Bakke also held that quotas cannot be used in voluntary affirmative action programs in admissions unless absolutely necessary. 1989: The U.S. Supreme Court held in City of Richmond v. Croson that the standard to be used in evaluating affirmative action programs in contracting was one of "strict scrutiny.

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