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Shaw v. Reno (1993)

AP.GOPO:
CON‑3.C.1 (EK)

Key points

  • 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.
  • 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).
The US Department of Justice, led by Attorney General Janet Reno, rejected North Carolina’s district plan, instructing the state assembly to add another majority-minority district in order to comply with recent amendments to the
Voting Rights Act
. The proposed second district was oddly-shaped, following along a highway for nearly the entire length of the state.
Map of North Carolina showing voting districts. The district in question in this case is long and snaking, following along a highway.
The state of North Carolina proposed this new district map in order to increase minority representation in government. District 12, shown here in pink, was an oddly-shaped district that followed a highway. Source: Wikimedia Commons
After the General Assembly passed legislation creating the second district, a group of white voters in North Carolina, led by Ruth O. Shaw, sued on the grounds that the district was an unconstitutional
gerrymander
. Shaw’s group claimed that drawing districts based on race violated the equal protection clause of the Fourteenth Amendment.

The Constitutional question at stake

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

Decision

Yes. In a 5-4 decision, 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. Although district plans may take racial considerations into account, and must meet the provisions of the Voting Rights Act, race cannot be the predominant factor in drawing districts.
Check your understanding
Based on the ruling in Shaw v. Reno (1993), which of the following scenarios would most likely violate the equal protection clause of the Fourteenth Amendment?
Choose 1 answer:
Choose 1 answer:

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.
Four of the justices in this case dissented from the majority opinion, citing two reasons: first, 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.

What do you think?

What are the advantages and disadvantages of majority-minority districts?
How are the cases Shaw v. Reno and Baker v. Carr similar? How are they different?

Want to join the conversation?

  • leaf blue style avatar for user Cameron Christensen
    I'm struggling with a phrase near the end: "[...] attempt to equalize treatment by providing minority voters with an effective voice in the political process." Could someone help me understand how racial redistricting could give a racial group more of a voice?
    (13 votes)
    Default Khan Academy avatar avatar for user
    • duskpin ultimate style avatar for user Harriet Buchanan
      I think an example could be made:

      If there were NO gerrymandering, and
      If that resulted in 3 districts with 2/3 white and 1/3 minority voters in each district
      It might result in NO minority Congressional Representatives (3 white), whereas;

      One gerrymandered district with mostly minorities, two with mostly white
      might result in 2 white and 1 minority Reps,
      and therefore a direct minority voice in Congress.

      I hope that helps.
      (43 votes)
  • blobby green style avatar for user nikhilmenghani12
    Would fixing gerrymandering by using the shortest-split line method be a good idea.
    (5 votes)
    Default Khan Academy avatar avatar for user
    • hopper cool style avatar for user megamanwhiz
      On one hand, using the shortest-split method would be completely unbiased and could prevent partisan and racial gerrymandering.

      On the other, a district that has been gerrymandered can provide a greater chance for minorities to get their views into the government. For more explanation, see Harriet Buchanan's answer to the question above.

      Hope this helps.
      (6 votes)
  • piceratops ultimate style avatar for user WhitUden
    Did the questioned reapportionment (with the snakelike 12th district) provide an advantage to the minority groups or to the white voters?
    (4 votes)
    Default Khan Academy avatar avatar for user
    • female robot amelia style avatar for user Sahinj01
      It gave an advantage to the minority group. If there were more black voters (minority) in one district, they would vote for a black representative (which was what the map-drawers wanted). It had good intentions to let a black person be a representative, but because it was drawn to separate people by race it was voted against. (Hope this helped)
      (3 votes)
  • blobby green style avatar for user brianna morales
    What would be the two conflicting constitutional principle?
    (4 votes)
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  • aqualine ultimate style avatar for user Jasmine Devera
    How does racial gerrymandering go against the 14th amendment's equal protection clause?
    (2 votes)
    Default Khan Academy avatar avatar for user
  • blobby green style avatar for user ra110220
    How would both views of the situation be similar.
    (0 votes)
    Default Khan Academy avatar avatar for user