In Adarand v. Pena, Adarand challenged a federal program that provided incentives to employers that employ individuals that are “economically and socially disadvantaged” (Alexander 149). Adarand, a subcontractor provided the lowest bid for a job, however due to the federal government’s financial incentives the contract was awarded to Gonzales, who was certified as a disadvantaged business. The Court in Adarand held that strict scrutiny should be applied to affirmative action or remedial programs that was based on race because similar arguments in previous case laws recur, such as “skepticism of race-based classifications” and “position on the question of benefits vs. burdens or race neutrality”(Alexander 150).