Elite universities will be returning to court to clarify the murky ruling in "Grutter v. Bollinger". Thomas E. Wood predicts that judges will again have to pass judgment on the constitutionality of dubious scheming by elite universities to achieve their critical mass of black students legitimately--without resort to tacit quotas and racial balances--from the minuscule pool of highly sought-after minority candidates. (Contains 3 tables and 4 notes.)