Shaw v Reno
North Carolina was given another seat in the House of Representatives after a new population census in 1990. This population increase meant that they had to rezone the areas to uphold the “one person, one vote” guarantee. With this, they drew a new district division plan with 2 majority-minority (population mostly of minority groups) districts that were supposed to proportionalize representation. This requirement for representative equilibrium was the Voting Rights Act of 1965. However, the plan looked very lopsided, which made it seem like there was some kind of consideration being made that skewed district shapes. Resident Richard Shaw sued Attorney General Janet Reno, claiming that the questionable rezoning violated Equal Protection rights of the Fourteenth Amendment.
Breakdown Verdict.
The 5-4 verdict determined a violation of individual rights, since the consideration of race was excessive and in turn created uneven districts. Written by Sandra Day O’Connor, the opinion determined that the division was nevertheless a case of gerrymandering (manipulation of electoral boundaries) even though it was meant to equalize race. Strict scrutiny, a test checking the constitutionality of an existing law, determined that the rezoning was not the “least restrictive” way to represent the area.
Result Going Forward.
The case expanded upon the utilization of the Voting Rights Act, which initially removed certain inequalities associated with voting. District rezoning in relation to population increase continues to be a conflict, since the line between equality and overcompensation–as seen in Shaw v Reno–continues to be drawn.
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