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Overview of Shaw v. Reno Case

May 5, 2025

Shaw v. Reno: Supreme Court Case Overview

Introduction

  • Focus on Shaw v. Reno, a required Supreme Court case in the AP Government curriculum.
  • Emphasis on gerrymandering, specifically racial gerrymandering.

Facts of the Case

  • 1990 Context:
    • North Carolina had no black representatives despite having a 20% black population.
    • After the 1990 census, North Carolina drew a majority black district and sought Justice Department approval.
    • Justice Department suggested creating a second majority black district.
  • Gerrymandering Definition:
    • Drawing congressional districts to favor one group over another.
    • Partisan Gerrymandering: favors one political party.
    • Racial Gerrymandering: favors one racial group.

Constitutional Principle

  • Voting Rights Act of 1965: Required certain states to get federal approval for district changes.
  • Equal Protection Clause of the 14th Amendment:
    • Shaw's Argument: Districts drawn with race in mind, violating the clause.
    • Reno's Argument: Districts aimed to help historically marginalized black residents, thus did not violate the clause.
    • Justice Department: Supports districts drawn to support marginalized groups for equity.

Court's Decision

  • Ruled against Reno and the Justice Department.
  • Reason:
    • Districts drawn solely on race are unconstitutional.
    • Sets a dangerous precedent for major racial groups to misuse gerrymandering.
    • Confirmed violation of the Equal Protection Clause of the 14th Amendment.

Importance of the Case

  • Precedent:
    • Shaw v. Reno set a precedent against racial gerrymandering.
    • Districts cannot be drawn with the sole intent to group voters by race.
    • Continues to be challenged but the decision remains upheld.

Conclusion

  • Shaw v. Reno remains a significant case in the context of electoral law and the equal protection clause.
  • Important for understanding limitations and regulations regarding gerrymandering.

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