Shaw v. Reno
Shaw v. Reno is a landmark U.S. Supreme Court case that addressed the constitutionality of a racially drawn congressional district in North Carolina designed to create a black majority. The district's unusual 150-mile shape raised concerns that its primary aim was to segregate voters based on race, prompting a legal challenge. In a narrow 5-4 ruling, the Court, led by Justice Sandra Day O'Connor, determined that the district could not withstand "strict scrutiny," a rigorous standard used to evaluate legislation impacting race. The majority opinion emphasized that the district's design likely served solely a racial purpose, invoking the equal protection clause of the Fourteenth Amendment. Dissenting justices argued that the district did not infringe on the rights of others, and that the case was not a valid use for such scrutiny.
The outcome of Shaw v. Reno set a significant precedent, making it more challenging for states to create racially motivated electoral districts, thus complicating efforts to ensure minority representation in legislative bodies. The ruling highlights ongoing tensions in U.S. electoral politics regarding race, representation, and the legal frameworks that govern them. Further developments in 2001 allowed for a redrawn district that still maintained a black majority, illustrating the complexities of balancing race and political representation in electoral law.
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Shaw v. Reno
Identification U.S. Supreme Court decision
Date Decided on June 28, 1993
The Court declared that voting districts based on race should be held to the legal standard of “strict scrutiny.”
This case dealt with a black majority North Carolina congressional district. The district stretched over a 150-mile-long area, and the design’s only purpose seemed to be to connect heavily black areas. A lawsuit ensued. The U.S. Supreme Court, in a 5-4 decision authored by Sandra Day O’Connor, ultimately held that the district was illegal, as it did not survive the “strict scrutiny” analysis, which holds that the questioned legislation must serve a “compelling government interest,” be “narrowly tailored,” and be the “least restrictive means” of accomplishing this goal.
The majority consisted of Chief JusticeWilliam H. Rehnquist and Justices O’Connor, Antonin Scalia, Clarence Thomas, and Anthony Kennedy. The Court held that as race was involved, the equal protection clause came into play. The Court also held that the district had a “bizarre shape”—making it likely that the only purpose of the district was a racial one. The Court then remanded the issue to a lower court to apply the strict scrutiny test.
The dissenters, consisting of Justices Harry A. Blackmun, David Souter, John Paul Stevens, and Byron White, argued that this case was different from other racial ones, as a racially weighted district did not deny anyone else his or her rights and that using the strict scrutiny test only in districts that favored minorities resulted in policies disfavoring minorities overall. The dissent essentially argued that since no one was harmed, the lawsuit should not have been allowed. The majority held, however, that a harm was done to the political body as a whole. It was also noted by the dissent that whites, not blacks, were the ones arguing in favor of reversing the district.
Impact
In 2001, after four more trips to the Supreme Court, a redrawn district (but still a black-majority one) was allowed. This shift was the result of two significant differences: First, evidence was the basis of the 2001 decision and the testing was against an evidentiary standard; and second, Justice O’Connor moved her vote from against the district to in favor of it.
The Shaw v. Reno decision still holds legal significance, and it puts a high bar in front of states who wish to create districts on racial grounds. It thus makes it difficult for a state to attempt to ensure minority representation in legislatures.
Bibliography
Canon, David T. Race, Redistricting, and Representation: The Unintended Consequences of Black Majority Districts. Chicago: University of Chicago Press, 1999.
Darling, Marsha J. Tyson, ed. Race, Voting, Redistricting, and the Constitution: Sources and Explorations on the Fifteenth Amendment. New York: Routledge, 2001.
Yarbrough, Tinsley E. Race and Redistricting: The Shaw-Cromartie Cases. Lawrence: University Press of Kansas, 2002.