Shaw v. Reno

Shaw v. Reno, 509 U.S. 630 (1993), is a landmark decision of the United States Supreme Court.

After the 1990 census, North Carolina created a congressional district that was bizarrely shaped (160 miles long, sometimes as narrow as an interstate highway) to connect Black communities and create a majority-Black district. White voters challenged the district as an unconstitutional racial gerrymander under the Equal Protection Clause.

Significance

Justice O’Connor’s 5-4 opinion held that redistricting plans that are ‘so bizarre on their face’ that they are ‘unexplainable on grounds other than race’ must be subjected to strict scrutiny. The Court found that the district’s extreme shape warranted such scrutiny. The decision opened the door to equal protection challenges to race-based redistricting, requiring states to show a compelling interest (such as complying with the Voting Rights Act) and narrow tailoring for districts drawn predominantly on the basis of race.

Category

US Federal Case Law