- Date:
- 1993
- Location:
- United States
Shaw v. Reno
-
What was Shaw v. Reno?
In Shaw v. Reno (1993), the U.S. Supreme Court ruled, 5–4, that electoral districts with boundaries unexplainable except as racial gerrymandering can be challenged. Such districts may violate the Fourteenth Amendment's equal protection clause.
The case arose after the 1990 census when North Carolina's legislature created a second majority-Black district at the U.S. Department of Justice's request. This district was challenged by white residents as racial gerrymandering. The Court, in Justice Sandra Day O’Connor's majority opinion, favored the plaintiffs, stating that redistricting plans that segregate voters by race and disregard district features can be challenged if lacking justification.
Post-Shaw v. Reno, race cannot be the sole reason for creating or changing a voting district.
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What issue did the Supreme Court need to decide in Shaw v. Reno?
In Shaw v. Reno, the central issue before the Supreme Court was whether North Carolina's redistricting plan, following the 1990 census, was an example of racial gerrymandering that violated the Fourteenth Amendment's equal protection clause. The state's plan created a second majority-Black district that was challenged by white residents as an effort to segregate voters based on race.
The Supreme Court ruled that districts with boundaries unexplainable except as racially motivated could be challenged. The Court stated that such plans, seemingly classifying voters by race, should be subject to strict scrutiny, requiring a compelling state interest and narrowly tailored means. Gerrymandering based on race is incompatible with Section 2 of the 1965 Voting Rights Act.
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Why was the shape of the North Carolina voting district important in this case?
In Shaw v. Reno, the shape of the North Carolina voting district was important because it was so irregular that it could only be explained as an effort to separate voters based on race. The district was unusually winding and narrow, with some parts no wider than the interstate highway it followed. The Supreme Court ruled that such districts, which disregard geographic compactness and contiguity, can be challenged as potential violations of the equal protection clause of the Fourteenth Amendment. This is because they appear to classify voters by race. The Court decided that race could not be the main factor in drawing electoral district boundaries.
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How did race play a role in the Shaw v. Reno case?
In Shaw v. Reno, race played a central role. The case challenged a North Carolina redistricting plan that created a majority-Black district, which was seen as an example of racial gerrymandering.
The Supreme Court ruled that districts that are drawn to segregate voters based on race can be challenged as potential violations of the equal protection clause of the Fourteenth Amendment. The Court stated that such redistricting plans must be held to the highest standard of judicial review, because they classify voters by race.
The decision has since served as a precedent in challenges to majority-minority voting districts.
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What did the Supreme Court decide about racial gerrymandering in this case?
In Shaw v. Reno (1993), the U.S. Supreme Court ruled, 5–4, that electoral districts that are unexplainable except as racial gerrymandering can be challenged as potential violations of the Fourteenth Amendment's equal protection clause. The Court held that redistricting plans that segregate voters by race, disregard district features, and lack justification can be challenged. Such plans, the Court determined, require strict scrutiny, needing a compelling state interest and narrow tailoring. While complying with the Voting Rights Act is an important interest, unconventional district designs might not be necessary for that purpose. The ruling set new justification standards for redistricting, limiting race as the sole basis for creating voting districts.
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How did Shaw v. Reno affect how voting districts are designed in the United States?
Shaw v. Reno (1993) significantly altered how voting districts are designed in the U.S. The Supreme Court ruled that districts with boundaries unexplainable except as racial gerrymandering could face challenges as potential violations of the Fourteenth Amendment's equal protection clause.
After this ruling, race could not be the sole factor in creating or modifying a voting district. The Court held that redistricting plans that effectively segregate voters based on race, while disregarding traditional district features, could be challenged if lacking sufficient justification. This decision set new standards requiring proper justification for redistricting, impacting the creation of majority-minority voting districts after 1993.
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Shaw v. Reno, legal case in which the U.S. Supreme Court ruled (5–4) on June 28, 1993, that electoral districts whose boundaries cannot be adequately explained except as examples of racial gerrymandering, or efforts to segregate voters on the basis of race, can be challenged as potential violations of the equal protection clause of the Fourteenth Amendment (1868) to the U.S. Constitution, which prohibits states from denying to any person the “equal protection of the laws.”
The case stemmed from a redistricting plan drawn up after the 1990 census by the state legislature of North Carolina. The plan created a second majority-Black district in the state at the behest of the U.S. Department of Justice, headed from 1993 to 2001 by Attorney General Janet Reno. This second majority-minority district, however, was winding and incongruous; some parts of it were only as wide as the interstate highway along which it proceeded. A group of five white residents of Durham county, North Carolina, headed by Ruth Shaw, challenged the redistricting plan in federal district court as an act of racial gerrymandering that violated various provisions of the Constitution, including the equal protection clause. The district court rejected the complaints, holding in particular that race-conscious redistricting is not unconstitutional per se, or in and of itself, and that the specific redistricting used to create the second Black-majority district in North Carolina did not violate the right of the state’s white population to equal protection of the laws, because the district was created with the purpose of preventing dilution of the voting power of Blacks in the state in keeping with Section 2 of the Voting Rights Act of 1965 (as amended in 1982) and because the redistricting plan did not similarly dilute the voting power of whites. The case was appealed directly to the Supreme Court, which heard oral arguments on April 20, 1993.
In a majority opinion written by Justice Sandra Day O’Connor, the Court ruled in favour of the plaintiffs, holding that redistricting plans that effectively segregate voters on the basis of race while disregarding conventional features of voting districts (such as geographical compactness and contiguity) and that lack “sufficient justification” can be challenged as possible violations of the equal protection clause. The Court held that, because they involve the apparent classification of voters by race, such plans should be subject to strict scrutiny, the highest standard of judicial review, which would require that the plan serve a compelling state interest and that it be the most narrowly tailored means of achieving that end. (Although North Carolina’s creation of a second Black-majority voting district did serve an important interest—that of complying with the Voting Rights Act by avoiding dilution of the Black vote in the state—a district of such an unconventional design was arguably not required for that purpose.) Although the Court agreed with the plaintiffs that the redistricting plan was challengeable under the equal protection clause, it did not find that the clause had in fact been violated; nor did it take any position on the general question of whether intentionally created majority-minority districts always give rise to equal-protection claims.
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In the aftermath of the Shaw v. Reno decision, redistricting was held to new standards of justification; in general, race could no longer be the sole basis for creating or modifying a voting district. The case was repeatedly used as a roadblock to the creation of majority-minority voting districts after 1993.