File: powell final for Darby 802 Created on: 3/15/2009 12:55:00 PM Last Printed: 4/3/2009 10:11:00 AM DENVER UNIVERSITY LAW REVIEW [Vol. 86.Obama and understanding.82 Though most of us are completely unaware of their influence on our subconscious, these biases affect how we perceive, interpret, and understand others’ actions.83 Because these attitudes— unrecognized on the conscious level but powerful at the subconscious level—influence choices and decisions, individual and institutional discrimination can occur even in the absence of blatant prejudice, ill will, or animus. This bias has been measured and documented in the Harvard Implicit Association Tests.84 This does not mean that we are all secretly racist. It does suggest, however, that we are complex and conflicted and that this conflict can be organized to make either our biases more salient or our equalitarian aspiration more salient. The Southern Strategy was designed to mobilize racial resentment and worked well from 1968 until the election of President Obama. We can challenge the nefarious effort to make our biases more salient, but we cannot do so by being race blind. As President Obama reminds us: If an internalization of antidiscrimination norms over the past three decades—not to mention basic decency—prevents most whites from consciously acting on [negative racial] stereotypes in their daily interactions with persons of other races, it’s unrealistic to believe that these stereotypes don't have some cumulative impact on the often snap decisions of who’s hired and who's promoted, on who’s arrested and who's prosecuted, on how you feel about the customer who just walked into your store or about the demographics of your children’s school.85 To address structural racialization, we must understand the work that our institutions and policies are in fact doing, not what we want or hope for them to do. In order to understand this, we must take seriously our group situatedness. I have already argued that a universal approach is likely to be ineffective. Others argue that targeted racial efforts are likely to fail in part because of the continuing racial resentment that targeted efforts create and preserve. For a sincere policy maker this suggests a difficult choice. Either avoid race and leave much of the existing racial practices and arrangements undisturbed, or deal with race and excite racial resentment that will undermine the policies and the electability of the politician. But there are powerful and effective alternatives to these two choices. One alternative is to learn a great deal about how to talk about race in ways that are not divisive. The second alternative is to make sure our institutions do the work we want them to do. This is done by adopting 82. Project Implicit, supra note 81. 83. Because of these implicit biases, identical actions or opinions of two people of different social groups often are interpreted differently, depending upon the group to which each belongs. See also Jerry Kang, Trojan Horses of Race, 118 HARV. L. REV. 1489 (2005). 84. Project Implicit, supra note 81. 85. OBAMA, AUDACITY OF HOPE, supra note 16, at 139.