Shaw v. Reno

Where was the Rule of Law or Legal Principle Applied?

If a reapportionment plan creates a district that is so irregular that the only reason for its creation is to separate voters based on race, then an Equal Protection challenge against that plan is valid.

Majority justices?

Justices Rehnquist, O'Connor, Scalia, Kennedy, Thomas

Majority summary opinion?

Legislation that classifies a person or group of people solely based on their race is, by its nature, a threat to a system that strives to achieve equality, the majority opined.

Petitoner of this case?

Ruth O. Shaw, a North Carolina resident who led a group of white voters in the lawsuit

Why is Shaw vs Reno important?

Shaw v. Reno is an important decision because it represents a conservative shift on the Court.

What was Justice Blackmun's dissent opinion?

The Court has abandoned settled law to decide this case. It is ironic that it does so when white voters challenge a law that would have North Carolina send a black representative to Congress for the first time since Reconstruction

Why did the District Court dismiss it?

They found that race-based districting is not prohibited by the Constitution.

Ruling in simple terms?

When a newly created district cannot be explained by means other than race, it is subject to strict scrutiny. A state must prove a compelling interest in order to survive a legal challenge to the redistricting plan.

Dissenting justices?

White, Blackmun, Stevens, Souter

Did the North Carolina residents who objected to the majority-minority district raise a valid question under the Fourteenth Amendment?

Yes; the Court agreed that the shape of the proposed district was so odd that there was no compelling explanation for its shape other than separating voters by race.

Why was Shaw v Reno an important decision in terms of minority representation?

the group claimed that the districts were racial gerrymanders that violated the equal protection clause of the Fourteenth Amendment. In its 1993 decision, the Supreme Court agreed, ruling that race cannot be the predominant factor in creating districts

Background of the case?

After the 1990 census, the North Carolina General Assembly redrew its congressional districts to account for changes in population. Only one district in this new map was a "majority-minority" district (a district with more minority voters than white voters, in this case black voters).

What did North Carolina argue?

An attorney on behalf of North Carolina argued that the general assembly had created the second district in an attempt to better comply with requests from the Attorney General in accordance with the Voting Rights Act. The VRA required an increase in the representation of minority groups. The U.S. Supreme Court and the federal government should encourage states to find ways to comply with the act, even if compliance results in oddly shaped districts, the attorney argued.

What prompted this?

As a result of the 1990 census, North Carolina became entitled to a 12th seat in the United States House of Representatives. To comply with Section 5 of the Voting Rights Act of 1965, North Carolina submitted a congressional reapportionment plan with one majority-black district to the U.S. Attorney General. The Attorney General objected to the plan on the ground that the second district could have been created to give effect to minority voting strength in the State's south-central to southeastern region.

What was argued?

In 1991, a group of white voters in North Carolina challenged the state's new congressional district map, which had two "majority-minority" districts. The group claimed that the districts were racial gerrymanders that violated the equal protection clause of the Fourteenth Amendment.

What was Souter's dissent opinion?

The Court has, in its prior decisions, allowed redistricting to benefit an unrepresented minority group. The fact that it now chooses to apply strict scrutiny when a law is meant to benefit a race that has been the subject of historical discrimination makes no sense.

Why does Shaw v. Reno matter?

The Court ruled that claims of racial redistricting must be held to a standard of strict scrutiny, meaning that any law that results in classification by race must have a compelling government interest, be narrowly tailored to meet that goal, and be the least restrictive means for achieving that interest.

What was Steven's dissent opinion?

here is no constitutional requirement of compactness or contiguity for districts. The Equal Protection Clause is only violated when a law seeks to hurt a minority group in voting.t

Why did four justices in this case dissent from majority opinion?

that the white voters who brought the suit could not prove they had been injured in any way by the redistricting plan, and second, that the redistricting plan was an attempt to equalize treatment by providing minority voters with an effective voice in the political process, not an attempt to strip voting power from a particular group.