Shaw v. Reno

The residents were represented by Robinson O. Everett, who argued that the state had gone too far in trying to secure a second black majority district. He argued that this new district, an awkward and unusual one that had no other purpose than to create a black majority, violated certain principles of reapportionment such as compactness, contiguousness, and community of interest. Everett concluded that the state had erred by drawing district boundaries in such a way as to target two seats for persons of a particular race.

The state's position, presented by H. Jefferson Powell, was that it had made an effort in good faith to carefully comply with both the Voting Rights Act legislation and the "one person, one vote" requirement (Reynolds v. Sims [1964]), by intentionally creating a second majority-minority district. He argued that states should be encouraged to comply with the Voting Rights Act.

The U.S. Supreme Court decided that the residents did raise a valid question under the Fourteenth Amendment's Equal Protection Clause, which prevents any state from discriminating against persons according to their race. The district court decision was reversed and remanded, although it was noted that the district court did properly dismiss their claims, and must now determine if there was some "compelling governmental interest" to justify this plan.

Justice O'Connor delivered the majority opinion of the Court, joined by Justices Rehnquist, Scalia, Kennedy, and Thomas. O'Connor noted in the opinion that the appellants' claim "must be examined against the backdrop of this country's long history of racial discrimination in voting." A racial gerrymander should be closely scrutinized so as to avoid stereotypical ideas about the preferences of voters of the same race, and state legislation that focuses on classifying citizens according to race "must be narrowly tailored to further a compelling governmental interest," since this type of racial classification can threaten "special harms." Furthermore, a covered jurisdiction cannot use section 5 of the Voting Rights Act to justify racial gerrymandering. For these reasons, the district court's decision was reversed and remanded.