In Adarand Constr. Inc. v. Pena, U.S. 115 S.Ct. 2097, 132 L.Ed.2d 158 (1995), the Supreme Court held that "all racial classifications ... must be analyzed under strict scrutiny." The Court in Adarand singled out Metro Broadcasting as a "significant departure" from much of the Equal Protection jurisprudence that had come before it, in part because it suggested that "benign" government race-conscious classifications should be treated less skeptically than others. In Adarand, the Supreme Court reasoned that " 'it may not always be clear that a so-called preference is in fact benign.' " Id.