Shaw v. Hunt

1996-06-13

Headline: Court strikes down North Carolina’s oddly shaped majority-black congressional district, ruling lawmakers used race as the dominant factor and the plan was not narrowly tailored.

Holding: The Court held that North Carolina’s second majority-black district violates the Equal Protection Clause because race was the predominant factor and the plan was not narrowly tailored to a compelling interest.

Real World Impact:

Invalidates District 12 and forces map redraws affecting voters' districts.
Reinforces that race cannot be the predominant factor in drawing districts.
Limits relying on the Justice Department’s preclearance demand as automatic justification.

Topics: racial gerrymandering, voting rights, congressional redistricting, district shapes

Summary

Background

After the 1990 census increased North Carolina’s congressional seats from 11 to 12, state lawmakers drew a plan that first created one majority-black district in the northeast and, after a Justice Department objection, added a second majority-black district in the Piedmont region. The two districts have highly irregular, serpentine shapes. Five North Carolinians sued state officials challenging the map; a federal trial court found the lines were deliberately drawn by race but upheld the plan as needed to comply with the Voting Rights Act.

Reasoning

The Court reviewed whether race was the predominant factor in drawing the second majority-black district and whether the classification was narrowly tailored to a compelling interest. The Justices concluded that race was the legislature’s dominant consideration and that the district was not narrowly tailored. The Court found the district was not required by the Department of Justice’s preclearance process and that the district could not remedy a vote-dilution problem because it was not geographically compact where a compact minority community existed. Only two plaintiffs who lived in that district had standing to challenge it. The Supreme Court reversed the lower court’s judgment.

Real world impact

The ruling invalidates the specific second majority-black district and requires redrawing that seat consistent with the Equal Protection Clause. It narrows the circumstances in which compliance with the Voting Rights Act or a preclearance objection can justify using race as the predominant factor. State legislatures, minority and majority voters, and future mapmakers will face clearer limits when race drives district lines.

Dissents or concurrances

Justice Stevens (joined by Justices Ginsburg and Breyer) dissented, arguing the legislature had reasonable, nonracial reasons (including incumbency protection, urban-rural communities of interest, and avoiding costly Voting Rights Act litigation) and that the plan should be upheld.