Shaw v. Reno (Shaw I) (1993) Case Brief: Supreme Court Rules Against Racial Gerrymandering in Congressional Districts

Case Brief: Shaw v. Reno [Shaw I], 509 U.S. 630 (1993)

Court: Supreme Court of the United States

Date: June 28, 1993

Facts: In Shaw v. Reno, the case arose from the state of North Carolina's redistricting plan following the 1990 Census. The North Carolina General Assembly created a congressional district that was unusually shaped, designed to increase the representation of African Americans in Congress. The plan resulted in a district that stretched across the state, creating a "racially gerrymandered" district.

Two white voters, Shaw and others, challenged the constitutionality of this district, arguing that it violated their rights under the Equal Protection Clause of the Fourteenth Amendment. They contended that the district was drawn predominantly based on race, which they claimed was unconstitutional.

Issue: Does a congressional district that is drawn predominantly based on race, to enhance minority representation, violate the Equal Protection Clause of the Fourteenth Amendment?

Holding: The Supreme Court held that the redistricting plan violated the Equal Protection Clause of the Fourteenth Amendment because it was drawn primarily on the basis of race.

Reasoning:

1. Racial Gerrymandering: The Court emphasized that while the government may consider race in redistricting to promote minority representation, race cannot be the predominant factor in creating district lines. The bizarre shape of the district suggested that race was the primary motivation for its creation.

2. Equal Protection Clause: The Court reiterated that the Equal Protection Clause prohibits the government from making decisions based solely on race. This case established that racially gerrymandered districts are subject to strict scrutiny, requiring a compelling governmental interest and a narrowly tailored approach.

3. Strict Scrutiny Standard: The Court applied the strict scrutiny standard, which requires that any racial classification must serve a compelling governmental interest and be implemented in the least restrictive manner. The state’s interest in enhancing minority representation was acknowledged, but it was not sufficient to justify the racial segregation evident in the district's design.

4. Historical Context: The Court acknowledged the historical context of racial discrimination and the importance of ensuring fair representation for minority groups. However, it asserted that this does not permit the state to create districts that are primarily drawn along racial lines.

Conclusion: The Supreme Court reversed the decision of the lower court, ruling that the North Carolina congressional district was unconstitutional due to its predominant reliance on race in its creation. The ruling reinforced the principle that while race may be considered in redistricting, it cannot be the primary factor, thereby maintaining the integrity of the Equal Protection Clause.