The "Ways and Means" column notes that a three-judge panel of the Michigan Court of Appeals last week ordered the Michigan Board of Canvassers to certify a November 2006 ballot measure that would amend the state's constitution to ban race- and gender-based preferences in university admissions. If approved by voters, the measure could preclude the University of Michigan from benefiting from its own landmark legal victory, a 2003 ruling upholding its law school's use of race-conscious admissions.