AP® United States Government and Politics · Unit 2 · Topic 2.3
Shaw v. Reno and Majority-Minority Districts
Shaw v. Reno (1993) held that when race is the predominant factor in drawing a district, courts must apply strict scrutiny under the Equal Protection Clause, even if the district helps a minority group.
After the 1990 census, North Carolina drew District 12 to create a second majority-Black district and comply with the Voting Rights Act. The district didn't look like a normal district. It snaked for about 160 miles along Interstate 85, narrowing in places to barely the width of the highway, reaching out to grab Black neighborhoods in Charlotte, Greensboro, Winston-Salem, and Durham while skipping over everyone in between. White voters in the district sued, arguing the shape itself proved the legislature had sorted people by race above all else.
The Court agreed that shape is evidence. A district that ignores compactness, contiguity, and existing political boundaries just to link up voters by race looks like racial gerrymandering, and that triggers strict scrutiny: the state must show the district is narrowly tailored to a compelling interest. Race can be one factor among many in redistricting without a problem. The violation happens when race becomes the predominant factor, overriding the traditional map-drawing principles a state would normally follow. Shaw didn't ask whether the district helped or hurt Black voters; it asked whether race explained the shape better than anything else did.
This builds on Baker v. Carr, which opened district lines to judicial review in the first place by ruling that redistricting is a justiciable question courts can hear. Shaw answers a narrower question Baker left open: once courts can look, what makes a map unconstitutional? The answer is predominant racial sorting, not the mere presence of a majority-minority district.
Key terms
- Strict scrutiny
- The highest level of judicial review, requiring the government to show a law or action is narrowly tailored to a compelling interest.
- Racial gerrymandering
- Drawing district lines where race is the predominant factor, overriding traditional districting principles.
- Majority-minority district
- A district drawn so that a racial or ethnic minority group makes up the majority of its voting population.
- Predominant factor
- The single consideration that outweighs all others in shaping a decision, here the main cause of a district's shape.
- Justiciable
- Capable of being decided by a court, as opposed to a political question courts refuse to hear.
Watch it explained
- How it worksDraw North Carolina's District 12 snaking along an interstate and show what it was collecting.
- How it worksHow does the Court separate race as a factor from race as the ONLY factor in a map?
- Ties togetherHow does Shaw v. Reno sit against Baker v. Carr on when courts may touch district lines?
- Common mistakeWhy isn't Shaw v. Reno a ruling that majority-minority districts are unconstitutional?
Check yourself
End of topic.