There is no constitutional requirement of compactness or contiguity for districts. Khan Academy Chapter 6 Flashcards | Quizlet Attorney General Janet Reno instructed the North Carolina state assembly to add another majority-minority district in order to comply with the recent amendments to the Voting Rights Act. The new district was described in Supreme Court's opinion as "snake-like. The decision was part of the Warren Court's series of major cases on civil rights in the 1950s and 1960s, and it is associated with establishing the "one person, one vote" rule. endobj 52 U.S.C. Bush administration rejected this plan on the grounds that it gave blacks insufficient congressional representation. When a district obviously is created solely to effectuate the perceived common interests of one racial group, elected officials are more likely to believe that their primary obligation is to represent only the members of that group, rather than their constituency as a whole. 0000004895 00000 n 478 U.S. 30 (1986). PDF AP U.S. Government: Required Foundational Documents - WordPress.com Yet, in this case, the voters in this case are not alleging that the white vote has been diluted. [22] It included that the Supreme Court of the United States and the federal government that allowed states to find any possible way to comply to the Voting Rights Act of 1965, even if it meant having a strangely structured district like this one which Reno argued against. PS: Political Science and Politics Under the Voting Rights Act, the State had to get approval for any congressional redistricting plan. 0000003021 00000 n Shaw v. Reno - Wikipedia SHAW v. RENO(1993) No. In his written opinion, Chief Justice John Marshall declared that "an act of the legislature repugnant to the Constitution is void." Baker v. Carr (1961) Established the "one-person, one-vote" principle that districts should be proportionately represented in Congress. See, e.g.,Rogers v. Lodge(1982);White v. Regester(1973). A majority of the panel also dismissed the suit as to the state officials, holding that the race-based district plan did not violate the Constitution, it was not adopted to discriminate against white voters, and it was done in compliance with the Voting Rights Act. Shaw v. Reno - Case Summary and Case Brief - Legal Dictionary Laws that explicitly distinguish between individuals on racial grounds fall within the core of that prohibition. Classifications of citizens on the basis of race "are by their very nature odious to a free people whose institutions are founded upon the doctrine of equality." If you're behind a web filter, please make sure that the domains *.kastatic.org and *.kasandbox.org are unblocked. In my view there is no justification for the Court's determination to depart from our prior decisions by carving out this narrow group of cases for strict scrutiny in place of the review customarily applied in cases dealing with discrimination in electoral districting on the basis of race. The district in question in this case is long and snaking, following along a highway. San Antonio Indep. In Shaw v. Reno (1993), the U.S. Supreme Court questioned the use of racial gerrymandering in North Carolina's reapportionment plan. endobj Congress, too, responded to the problem of vote dilution. Ruth Shaw and four other white North Carolina voters filed suit against the U.S. attorney general and various North Carolina officials, claiming that race-based redistricting violated, among other provisions, the Fourteenth Amendment's Equal Protection Clause. This was due to the establishment of the Fourteenth Amendment, which granted citizenship and equal rights to all African-Americans. At the time, North Carolinas voting-age population was 78% White, 20% Black, 1% Indigenous, and 1% Asian. 71 0 obj The Attorney General formally objected to the plan, arguing that a second majority-minority district could be created in the south-central to the southeastern region to empower Indigenous voters. It is unnecessary for us to decide whether or how a reapportionment plan that, on its face, can be explained in nonracial terms successfully could be challenged. If you're seeing this message, it means we're having trouble loading external resources on our website. I respectfully dissent. The purpose of "one person, one vote" is that "one man's vote in a congressional election would be worth as much as another's." 84 0 obj That argument strikes a powerful historical chord: It is unsettling how closely the North Carolina plan resembles the most egregious racial gerrymanders of the past. Justice OConnor noted that there are some rare circumstances where a law can appear racially neutral, but cannot be explained through anything but race; North Carolinas reapportionment plan fell into this category. to apply to redistricting - established "one person one vote" doctrine "the political thicket" (i.e. XIV, 1 provides that no state shall deny to any person within its jurisdiction the equal protection of the laws. <>/Border[0 0 0]/Rect[81.0 97.3415 156.704 105.3495]/Subtype/Link/Type/Annot>> publications and programs, please see the APSA website. "[15], After the General Assembly passed legislation creating the second district, a group of White voters in North Carolina, led by Ruth O. Shaw, sued on the grounds that the district was an unconstitutional gerrymander. The State of North Carolina, in response to the U.S. Attorney Generals, Five white North Carolina voters sued, alleging that the States, The District Court dismissed the suit, finding that race-based districting is not prohibited by the, The U.S. Supreme Court reversed that decision, holding that the case should not have been dismissed because the voters made a valid claim under the. HSn0|W( contemporary political phenomena by authors working within their own Arizona State Legislature v. Arizona Independent Redistricting Commission, Virginia House of Delegates v. Bethune-Hill. of Elections, 393 U. S. 544, 569 (1969) (emphasis added). Ruth O. Shaw (appellee) was a white Democratic resident of the 12th district in North Carolina. Justice Souter noted that the Court seemed to be suddenly applying strict scrutiny to a law that aimed to increase representation amongst a historically discriminated group. Supreme Court cases, which build on Shaw, focus on majority-minority districts and try to answer if race can be used to redistrict districts. 0000007872 00000 n The US Department of Justice, led by Attorney General. Shaw v. Reno - 509 U.S. 630, 113 S. Ct. 2816 (1993) Rule: The Equal Protection Clause, U.S. Const. Following is the case brief for Shaw v. Reno, 509 U.S. 630 (1993) Case Summary of Shaw v. Reno: The State of North Carolina, in response to the U.S. Attorney General's objection that it had only one majority-black congressional district, created a second majority-black district. 0000039011 00000 n Racial classifications of any sort pose the risk of lasting harm to our society. <>stream The general assembly took another look at the maps and drew in a second majority-minority district in the north-central region of the state, along Interstate 85. trailer The VRA required an increase in the representation of minority groups. How would both views of the situation be similar. However, five white North Carolina voters filed a lawsuit against federal and state officials. In addition, any affected American citizen that felt that they are being affected by the Voting Rights Act can file a lawsuit stating that it violates Section 2 of the Voting Rights Act which led rise to the case. Residents objected to the re-apportionment plan, and five White residents from Durham County, North Carolina, led by Ruth O. Shaw, filed suit against the state and the federal government. Many of these cases are controversial or were decided 5-4. Nor, because of the distinctions between the two categories, is there any risk that Fourteenth Amendment districting law as such will be taken to imply anything for purposes of general Fourteenth Amendment scrutiny about "benign" racial discrimination, or about group entitlement as distinct from individual protection, or about the appropriateness of strict or other heightened scrutiny. endstream "Shaw v. Reno: Supreme Court Case, Arguments, Impact." Shaw v. Reno | Definition, Background, Majority Opinion, & Facts Therefore, it should not apply to the White voters who brought this case. For these reasons, we conclude that a plaintiff challenging a reapportionment statute under the Equal Protection Clause may state a claim by alleging that the legislation, though race-neutral on its face, rationally cannot be understood as anything other than an effort to separate voters into different districts on the basis of race, and that the separation lacks sufficient justification. Shaw v. Reno (1993) (article) | Khan Academy She has also worked at the Superior Court of San Francisco's ACCESS Center. [16], The Voting Rights Act of 1965 lead to the rise of the Shaw v. Reno court case which allowed for more representation of the Black (minority) representation in the state of North Carolina. The Equal Protection Clause is only violated when a law seeks to hurt a minority group in voting. Croson Co.(1989) (city contracting);Wygant v. Jackson Bd. 0000005694 00000 n Allen v. State Board of Elections(1969) (emphasis added). endobj The White North Carolina voters could not show that they were disenfranchised as a result of the second, oddly shaped majority-minority district, Justice White wrote. 67 0 obj In Bush v. Vera, the state of Texas planned to add additional congressional districts after the 1990 census. The message that such districting sends to elected representatives is equally pernicious. 69 0 obj 78 0 obj of Elections, Wisconsin Legislature v. Wisconsin Elections Commission. LEAGUE OF UNITED LATIN AMERICAN CITIZENS v.PERRY After the 1990 census, the North Carolina General Assembly was entitled to a 12th seat in the U.S. House of Representatives and redrew its congressional districts to account for the changes in population. It is true, of course, that one's vote may be more or less effective depending on the interests of the other individuals who are in one's district, and our cases recognize the reality that members of the same race often have shared interests. Tinker v. Des Moines Independent Community School District (1969), New York Times Co. v. United States (1971), Citizens United v. Federal Election Commission (2010). This district would be North Carolina's second "majority-minority" district of majority Black voters. It is known as the "one person, one vote" case. Shaw v. Reno | Online Resources - SAGE Publications Inc Assembly of Colorado, Board of Estimate of City of New York v. Morris, Harris v. Arizona Independent Redistricting Commission, Mississippi Republican Executive Committee v. Brooks, Houston Lawyers' Association v. Attorney General of Texas, Bethune-Hill v. Virginia State Bd. %%EOF h0dp0d-?+X.ItHg'6Hx50W;{nJc2u$fPvc]r+T+r;O9K_,^|[ Y In whatever district, the individual voter has a right to vote in each election, and the election will result in the voter's representation. The Court today chooses not to overrule, but rather to sidestep,UJO. Racial Gerrymanding and the 14th Amendment, Wikimedia Commons / United States Department of the Interior. Shaw v. Reno (1993) The principle of "one person, one vote" was established by the Supreme Court in the 1960s. Shaw v. Reno - Constitutional Law - University of Central Florida Because the holding is limited to such anomalous circumstances, it perhaps will not substantially hamper a State's legitimate efforts to redistrict in favor of racial minorities. A reapportionment plan that includes in one district individuals who belong to the same race, but who are otherwise widely separated by geographical and political boundaries, and who may have little in common with one another but the color of their skin, bears an uncomfortable resemblance to political apartheid. H1n0Ew'`/8'e-9,>HX^c!+ If any state wanted to change any voting rules, they had to receive pre-clearance to ensure no new rule was racist. alter the basic ground rules of 'one person, one vote'." This alleged . Shaw v. Reno: Supreme Court Case, Arguments, Impact. League of United Latin American Citizens v. Perry, consolidated with 72 0 obj Some southern states filed against majority-Black districts. According to the residents' complaint, racial gerrymandering prevented voters from participating in a color-blind voting process. observations and information about the discipline. The majority found that North Carolinas twelfth district was so extremely irregular that its creation suggested some sort of racial bias.

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