On October 10, 2012, the Supreme Court of the United States heard oral argument in Fisher v. University of Texas at Austin—the latest challenge to race-conscious affirmative action university admissions programs. Court watchers highlighted that during the hearing, the Justices spent considerable time attempting to understand the meaning of a “critical mass” of minority students enrolled in universities and registered for individual courses. Critical mass emerged from the Justices’ questions in oral argument in a sort of catch-22. On one hand, it faced critiques that it lacked a quantifiable threshold that judges could review. Any attempts, however, to quantify critical mass would place the concept into the unconstitutional realm of impermissible quotas.