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Shaw vs. Reno

Background

  • Name of the Case: Shaw v. Reno
  • Year Decided: 1993
  • Facts: The U.S. Attorney General rejected a North Carolina congressional redistricting plan because it created only one black-majority district. North Carolina submitted a second plan creating two black-majority districts, but one of these districts was unusually shaped, stretching 160 miles across the state, connecting black populations in a narrow manner. This plan was challenged in court.
  • Issue: The issue was whether the creation of such an oddly shaped, race-based congressional district violated the Equal Protection Clause of the Fourteenth Amendment.
  • Decision The Supreme Court held that the district's bizarre shape, which was racially motivated, did raise a valid constitutional issue under the Equal Protection Clause.
  • Majority Decision Reasoning: The Court reasoned that race-based redistricting, as evident in the peculiar shape of the district, must be held to a standard of strict scrutiny. This meant that the district had to be narrowly tailored to serve a compelling state interest. The majority believed that the district's shape was so irregular that it could only be understood as an effort to segregate voters based on race, which is inherently suspect.
  • Dissenting Opinion Reasoning: The dissent argued that the district was an attempt to address historical political disenfranchisement and that the majority's decision undermined efforts to ensure minority groups could elect representatives of their choice.
  • Impact of the Case: Shaw v. Reno had a significant impact on the way districts are drawn in the United States, especially regarding the consideration of race in redistricting. It established that race-based redistricting must meet strict scrutiny standards, thus affecting how states approach the creation of minority-majority districts to ensure compliance with both the Voting Rights Act and the Equal Protection Clause.

Questions

  • Why does the majority opinion describe the peculiar shape of the Twelfth District?

    The majority opinion highlights the peculiar shape of the Twelfth District to illustrate how race was the predominant factor in its creation. The unusual, elongated shape of the district, which connected distant African American populations via narrow land corridors, was seen as evidence that the district was designed with the primary intent of segregating voters by race. This raised constitutional concerns under the Equal Protection Clause because it suggested that the state was valuing voters differently based on race, which required strict scrutiny to justify.

  • How did the Voting Rights Act protect African Americans in exercising the right to vote guaranteed by the 15th amendment?

    The Voting Rights Act of 1965 aimed to overcome legal barriers at the state and local levels that prevented African Americans from exercising their right to vote as guaranteed by the 15th Amendment. It did so by prohibiting racial discrimination in voting, eliminating literacy tests and other discriminatory practices used to disenfranchise African American voters, and, in certain cases, requiring jurisdictions with a history of discrimination to obtain federal approval before changing voting laws or practices (preclearance). This ensured that African Americans could register to vote and participate fully in the electoral process.

  • How does Justice White use statistics to contrast voting rights of whites with those of African Americans under the redistricting plan?

    Justice White, in his opinions related to cases like Shaw v. Reno, would often use statistical evidence to highlight disparities in voting power and representation between whites and African Americans under various redistricting plans. By presenting data on voter registration, turnout rates, and election results, he aimed to show how certain redistricting plans could dilute the voting strength of African American communities or enhance their ability to elect representatives of their choice, contrasting this with the impact on white voters. This method helped illustrate the tangible effects of redistricting on minority voting rights.

  • How did the facts in the Shaw case differ from those of the Wright decision? According to the dissent, why is it important to consider the intent of the legislature in creating minority-majority districts?

    The Shaw case differed from the Wright decision (a previous case that might be referenced for comparison) primarily in its focus on the constitutionality of race-based redistricting that resulted in bizarrely shaped electoral districts. While the specifics of the Wright decision would need further detail for a direct comparison, Shaw v. Reno was distinct in its examination of an extreme example of gerrymandering for racial purposes. According to the dissent in Shaw, considering the intent of the legislature in creating minority-majority districts was crucial to understanding the context of redistricting efforts aimed at remedying historical discrimination and ensuring equitable representation. The dissent argued that without considering legislative intent, efforts to empower minority voters and correct past injustices could be unfairly hindered, emphasizing the need for a nuanced approach that recognizes the difference between discriminatory and remedial uses of race in redistricting.