Shaw v. Reno

Facts of the Case

Following the 1990 census, the North Carolina state legislature enacted a reapportionment plan for the state’s seats in the United States House of Representatives, which plan created one irregularly-shaped, majority-black congressional district in the northeastern part of the state. The Attorney General of the United States, to whom the plan was submitted for preclearance under 5 of the Voting Rights Act of 1965, objected to the plan on the ground that the legislature could have created a second district with a majority of minority-group voters in the southeastern part of the state, with lines no more irregular than those of other districts in the plan, but had declined to do so for pretextual reasons. The state legislature then enacted a revised plan creating a second majority-black district in the north central part of the state, which district followed, and in some places was no wider than, an interstate highway. Individuals who resided and were registered to vote in a certain county, part of which lay in the new district, filed an action in the district court seeking declaratory and injunctive relief against various federal and state officials, which action alleged that the revised reapportionment plan created a racial gerrymander in violation of the equal protection clause of the Federal Constitution’s Fourteenth Amendment. The district court dismissed the complaint contending that favouring minority voters was not discriminatory and the plan did not lead to proportional underrepresentation of white voters statewide.

Question

Did the North Carolina residents’ claim, that the State created a racially gerrymandered district, raise a valid constitutional issue under the Fourteenth Amendment’s Equal Protection Clause?

CONCLUSION

Yes. The Court held that although North Carolina’s reapportionment plan was racially neutral on its face, the resulting district shape was bizarre enough to suggest that it constituted an effort to separate voters into different districts based on race. The unusual district, while perhaps created by noble intentions, seemed to exceed what was reasonably necessary to avoid racial imbalances. After concluding that the residents’ claim did give rise to an equal protection challenge, the Court remanded – adding that in the absence of contradictory evidence, the District Court would have to decide whether or not some compelling governmental interest justified North Carolina’s plan.

Case Information

  • Citation: 509 US 630 (1993)
  • Argued: Apr 20, 1993
  • Decided Jun 28, 1993