Shaw v. Reno

Shaw v. Reno, Supreme Court, 1993

Facts of the Case

After the 1990 census, North Carolina gained a 12th seat in the House of Representatives. The state submitted a redistricting plan that included one majority-black district. The U.S. Department of Justice rejected the plan, suggesting the creation of a second majority-black district to comply with the Voting Rights Act. North Carolina’s revised plan included an oddly shaped district that was 160 miles long and, at some points, no wider than the interstate road it followed. Several white voters, led by Ruth O. Shaw, challenged the constitutionality of the district, arguing that it was racially gerrymandered and violated the Equal Protection Clause of the Fourteenth Amendment.

Constitutional Question

Does the creation of a racially gerrymandered district violate the Equal Protection Clause of the Fourteenth Amendment?

Arguments

For Shaw (the plaintiffs):

  • The bizarrely shaped district was drawn solely based on race, which constitutes racial gerrymandering.
  • The district’s shape and construction are clear indications of an attempt to segregate voters into districts based on race, violating the principle of equal protection under the law.
  • Racial gerrymandering undermines the concept of a color-blind Constitution and promotes racial divisions rather than equality.

For Reno (Attorney General, representing the Department of Justice):

  • The creation of majority-minority districts is a legitimate effort to comply with the Voting Rights Act and ensure minority representation in Congress.
  • The district’s shape is justified by the need to include geographically dispersed black communities to create a majority-black district.
  • The plan should be upheld as a measure to enhance the political power of historically marginalized racial minorities.

The Decision

The Supreme Court, in a 5-4 decision, ruled in favor of Shaw. Justice Sandra Day O’Connor, writing for the majority, held that although race-conscious redistricting is not inherently unconstitutional, the bizarrely shaped district in this case exceeded what was reasonably necessary to avoid racial discrimination. The Court found that redistricting based predominantly on race without sufficient justification violates the Equal Protection Clause. The decision emphasized that racial gerrymandering threatens to perpetuate the notion that voters should be segregated by race.

Significance

Shaw v. Reno is a landmark case that established the precedent that redistricting based predominantly on race must be held to a standard of strict scrutiny under the Equal Protection Clause. The ruling clarified that while states must comply with the Voting Rights Act and consider race to some extent in redistricting, they cannot use race as the sole or predominant factor without a compelling state interest. This decision has had significant implications for redistricting practices, emphasizing the need for careful consideration to avoid racial gerrymandering and ensuring that districts are drawn in a manner that promotes equality and fairness.