Shaw v. Reno, 1993
Facts of the case
The U.S. Attorney General rejected a North Carolina congressional reapportionment plan because the plan created only one black-majority district. North Carolina submitted a second plan creating two black-majority districts. One of these districts was, in parts, no wider than the interstate road along which it stretched. Five North Carolina residents challenged the constitutionality of this unusually shaped district, alleging that its only purpose was to secure the election of additional black representatives. After a three-judge District Court ruled that they failed to state a constitutional claim, the residents appealed and the Supreme Court granted certiorari.
The U.S. Attorney General rejected a North Carolina congressional reapportionment plan because the plan created only one black-majority district. North Carolina submitted a second plan creating two black-majority districts. One of these districts was, in parts, no wider than the interstate road along which it stretched. Five North Carolina residents challenged the constitutionality of this unusually shaped district, alleging that its only purpose was to secure the election of additional black representatives. After a three-judge District Court ruled that they failed to state a constitutional claim, the residents appealed and the Supreme Court granted certiorari.
Constitutional Question
Did the North Carolina residents' claim, that the State created a racially gerrymandered district, raise a valid constitutional issue under the Fourteenth Amendment's Equal Protection Clause?
Did the North Carolina residents' claim, that the State created a racially gerrymandered district, raise a valid constitutional issue under the Fourteenth Amendment's Equal Protection Clause?
Decision: Yes for Shaw 5-4
The Court ruled for Shaw not because race was a factor but that it was the only factor for the odd shape. Using race as the only factor violated the idea of color-blind US law. Race may be a factor but certainly not the only factor and legislative district drawings must be held to strict scrutiny.
The Court ruled for Shaw not because race was a factor but that it was the only factor for the odd shape. Using race as the only factor violated the idea of color-blind US law. Race may be a factor but certainly not the only factor and legislative district drawings must be held to strict scrutiny.
Dissents: the district did not dilute or change the weights of other district votes (ie, Baker v. Carr), minority voters may benefit from a majority-minority districts created and were balanced by the fact many other districts were majority white districts.