# Shaw v. Reno The case that turned the Equal Protection Clause into a weapon against majority-minority districts. Decided June 28, 1993 by a 5–4 vote, *Shaw v. Reno* held that a redistricting plan so bizarre on its face that it can only be understood as an effort to separate voters by race may state a claim under the Equal Protection Clause — even when drawn to *help* minority representation. The case concerned North Carolina's snake-like 12th Congressional District, which followed Interstate 85 to link Black communities into a majority-Black district. ## The Holding Justice [[Sandra Day O'Connor]]'s majority opinion held that race cannot be the "predominant factor" in drawing district lines without triggering strict scrutiny, regardless of intent. The irony at the heart of the case — and the dissent's central objection — is that the district was created in part to comply with the [[Voting Rights Act of 1965]] and to remedy a history of minority vote dilution recognized in [[Thornburg v. Gingles]] (1986). *Shaw* thus put mapmakers in a vise: the VRA could require attention to race, while the Equal Protection Clause punished it. ## Significance *Shaw* established the "race as predominant factor" framework that the contemporary Court has wielded to dismantle minority-opportunity districts. It is the doctrinal foundation later deployed in [[Louisiana v. Callais]] (2026) to recast majority-minority districts as constitutionally suspect — the inverse of the VRA's original purpose. In the vault's account, *Shaw* sits at the hinge between the Voting Rights line ([[Thornburg v. Gingles]] → [[Shelby County v. Holder]] → [[Allen v. Milligan]] → [[Louisiana v. Callais]]) and the colorblind-constitution project: it is where "colorblindness" was first turned against the remedies designed to enfranchise Black voters. ## See Also - [[Gerrymandering]] — The redistricting practice at issue - [[Thornburg v. Gingles]] — The VRA vote-dilution framework *Shaw* complicated - [[Louisiana v. Callais]] — Where *Shaw*'s "predominant factor" test was weaponized - [[Voting Rights Act of 1965]] — The statute mapmakers were trying to satisfy