Shaw v. Reno

Shaw v. Reno
Argued April 20, 1993
Decided June 28, 1993
Full case nameRuth O. Shaw, et al., Appellants v. Janet Reno, Attorney General of the United States et al.
Citations509 U.S. 630 (more)
113 S. Ct. 2816; 125 L. Ed. 2d 511; 61 U.S.L.W. 4818; 1993 U.S. LEXIS 4406
Case history
PriorShaw v. Barr, 808 F. Supp. 461 (E.D.N.C. 1992)
SubsequentOn remand, Shaw v. Hunt, 861 F. Supp. 408 (E.D.N.C. 1994); reversed, 517 U.S. 899 (1996); Hunt v. Cromartie, 526 U.S. 541 (1999); Easley v. Cromartie, 532 U.S. 234 (2001).
Holding
Redistricting based on race must be held to a standard of strict scrutiny under the Equal Protection Clause while bodies doing redistricting must be conscious of race to the extent that they must ensure compliance with the Voting Rights Act.
Court membership
Chief Justice
William Rehnquist
Associate Justices
Byron White · Harry Blackmun
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Case opinions
MajorityO'Connor, joined by Rehnquist, Scalia, Kennedy, Thomas
DissentWhite, joined by Blackmun, Stevens
DissentBlackmun
DissentStevens
DissentSouter

Shaw v. Reno, 509 U.S. 630 (1993), was a landmark United States Supreme Court case in the area of redistricting and racial gerrymandering. After the 1990 census, North Carolina qualified to have a 12th district and drew it in a distinct snake-like manner to create a "majority-minority" Black district. From there, Ruth O. Shaw sued to challenge this proposed plan with the argument that this 12th district was unconstitutional and violated the Fourteenth Amendment under the Equal Protection Clause. In contrast, Janet Reno, the Attorney General, argued that the district would allow for minority groups to have a voice in elections. In the decision, the court ruled in a 5–4 majority that redistricting based on race must be held to a standard of strict scrutiny under the Equal Protection Clause and on the basis that it violated the Fourteenth Amendment because it was drawn solely based on race.

Shaw was an influential case that played a role in deciding important voting rights cases, including Bush v. Vera and Miller v. Johnson. Some southern states have continued to file against majority-Black districts. The North Carolina districts have been considered by the Supreme Court at least five times, and were redrawn in 2010 after Republicans gained control of the state legislature. There have been few attempts to study empirically whether gerrymandering procedures have advanced the goals of the Shaw.