Shaw v. Reno, 509 U.S. 630 (1993), was a landmark United States Supreme Court case in the area of redistricting and racial gerrymandering.

From there, Ruth O. Shaw sued to challenge this proposed plan with the argument that this 12th district was unconstitutional and violated the Fourteenth Amendment under the clause of equal protection.

However, the phrasing of irregularly drawn districts has left room for much interpretation, letting judges use their opinions rather than relying on Shaw.

[7] Section 2 of this act opposes using discriminatory voting practices in the election process and that in itself prohibits gerrymandering based on race.

[8] In 1870, following the Civil war and the abolishment of slavery, the 15th amendment was passed, giving all United States citizens the right to vote regardless of race, color, or previous conditions of servitude.

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.

Attorney General Janet Reno instructed the North Carolina state assembly to add another majority-minority district to comply with the recent amendments to the Voting Rights Act.

Shaw's group claimed that drawing districts based on race violated the equal protection clause of the Fourteenth Amendment.

However, five White residents of North Carolina, opposed against the redrawing because of the oddly shaped district in which they also stated it violated their Equal Protection Rights.

A federal District Court dismissed a lawsuit by North Carolina voters on the grounds that they had no claim for relief under a standard set by Carey.

The United Jewish Organizations of Williamsburg claimed that the plan violated their constitutional rights because the districts had been assigned solely on a racial basis.

The court found that the reapportionment plan was valid under the Constitution as the Fourteenth and the Fifteenth Amendment do not prohibit the use of racial factors in districting and apportionment.

Another argument that was made was the "snake-like" structure of the district and how it does not follow the reapportionment guidelines, which led to filling a lawsuit against both the state and federal government for political gerrymandering.

This was to designed to prevent any discrimination by race and North Carolina thought this plan was completely aligned with the request of the General Assembly guidelines.

In a 5–4 decision the courts ruled in favor of Shaw (the petitioner), finding that it was, in fact, unlawful to gerrymander on the basis of race.

In it, she writes that the court found that the shape of North Carolina's 12th district was so "bizarre" that the only reasonable explanation was that it had been drawn on the basis of race.

The courts also noted that based on the Voting Rights Act, race can be taken into account when redistricting plans are made, but it cannot be the sole factor when drawing a new district because that would violate the fourteenth amendment.

He detailed that the 12th district was ultimately drawn to benefit a minority group hence making the strict scrutiny applied to feel unreasonable.

[2] These redistricting measures were found to be unconstitutional and in the decision of this case, Justice Sandra Day O'Connor referred back to her opinion from Shaw v.

In Miller v. Johnson, Georgia's racial gerrymandering was questioned to violate the Equal Protection Clause, as it aimed to create a majority-Black district.

It is, therefore, unclear how to prove when a shape is bizarre enough to constitute a clear racial motive, making it hard for courts to decide on rulings.