Required caseVoting Rights & Equal Protection

Shaw v. Reno

1993·Unit 2: Interactions Among Branches of Government

Racial gerrymandering that sorts voters by race may violate the Equal Protection Clause even when intended to help minority representation.

Practice the comparison FRQRead the brief
Decided
1993
Clause at issue
Fourteenth Amendment: Equal Protection Clause
Course unit
Unit 2
Case number
11 of 14

Case brief

The three pieces every AP answer about this case should get right.

  1. 1

    The facts

    North Carolina created a highly irregular congressional district drawn primarily to concentrate African American voters.

  2. 2

    The constitutional question

    Does a bizarrely shaped majority-minority district drawn predominantly on the basis of race violate the Equal Protection Clause?

  3. 3

    The holding

    The Court ruled that such districts are subject to strict scrutiny and remanded the case for further review.

Why it matters

  • Redistricting driven primarily by race triggers Equal Protection analysis.
  • Irregular districts drawn to separate voters by race cannot escape constitutional scrutiny.
  • The decision limited race-conscious districting while leaving room for Voting Rights Act compliance.

Check yourself

Three questions on Shaw v. Reno: the holding, a common mix-up, and how it differs from another required case.

Question 1 of 3

In Shaw v. Reno (1993), the Supreme Court said that a North Carolina congressional district drawn in a bizarre shape must be reviewed under strict scrutiny if

SCOTUS comparison FRQ

Can you connect Shaw v. Reno to a case you’ve never seen?

The exam hands you an unfamiliar case and asks how it relates to a required one. Practice that here: name the shared principle, state the holding, and explain the connection.

Start the comparison

You’ll compare it with

Miller v. Johnson (1995)

Three parts

  1. A. Identify the shared principle
  2. B. Describe the required case
  3. C. Explain the connection

Frequently asked questions

What was wrong with the North Carolina district?

Its shape was so irregular that race was the obvious reason for the lines. The state had drawn it to concentrate African American voters. The Court said a map explained primarily by race has to face strict scrutiny under the Equal Protection Clause.

Did the Court ban majority-minority districts?

No. It remanded the case. A district drawn with race in mind is not automatically void, but the state must justify using race as the predominant factor. Shaw is a scrutiny case, not a flat ban.

How is Shaw different from Baker v. Carr?

Baker asks whether courts may hear a claim that districts have unequal populations. Shaw asks whether sorting voters by race violates equal protection. Unequal headcounts and racial line-drawing are different defects.

What should a comparison answer include?

Shaw is required. Use the bizarre district, the Equal Protection Clause, and the holding that race-predominant districting gets strict scrutiny.

The other required cases