found by a 5–4 margin that the affirmative action policies of the University of Michigan Law School were constitutional. But at the same time, it found by a 6–3 margin in the Gratz case that the undergraduate admissions policies of Michigan were not narrowly tailored to a compelling interest in diversity and 20 predetermined points are awarded to underrepresented minorities, and thus that they violated the Equal Protection Clause of the Fourteenth Amendment. In 2006, affirmative action in university admissions in the state of Michigan was banned by a ballot initiative known as the Michigan Civil Rights Initiative. President of Columbia As president (nicknamed "PrezBo" by students), Bollinger has attempted to expand the international scope of the University, taking frequent trips abroad and inviting world leaders to its campus. Bollinger has been criticized for taking a neutral public position on controversies regarding the Middle East Languages and Cultures (MEALAC) department and for placing the department in receivership. He has also been the subject of criticism for his role in advocating the expansion of the university into the Manhattanville neighborhood and the possible use of eminent domain to help it seize property there. The Bollinger administration's expansion plans have been criticized as fundamentally incompatible with the 197/a plan for development crafted by the community, and for failing to address the neighborhood's need to maintain affordable housing stock. President Bollinger has lived in the Columbia President's House since February 2004, after the building underwent a $23 million renovation. In February 2022, the Columbia Spectator reported that he had purchased an Upper West Side apartment for $11.7 million. In 2008, his salary was $1.7 million. In 2013, Bollinger's total compensation was $4.6 million, making him the highest paid private college president in the United States. Bollinger's residence has been the site of demonstrations in which his high salary was criticized as an example of the university's "inequitable allocation of resources." In a January 2021 rally during a student tuition strike protesting the university's tuition rates, Young Democratic Socialists of America organizers cited as further evidence of alleged inequitable allocation of university resources the fact that Bollinger's salary had been frozen that year, while the Barnard College administration's salaries had been cut, including by 20 percent in the case of the Barnard College president, Sian Beilock. In November 2006, Bollinger was elected to the Board of Directors of the Federal Reserve Bank in New