Racial gerrymandering occurs when a legislature draws district boundaries with race as the predominant factor, rather than for partisan, geographic, or other neutral reasons. Courts apply strict scrutiny to racial gerrymanders under the Equal Protection Clause of the 14th Amendment. The Supreme Court established this doctrine in Shaw v. Reno (1993) and Miller v. Johnson (1995). To win a racial gerrymandering claim, plaintiffs must show that race was the predominant — not just a contributing — factor in drawing the challenged district lines. If proven, the state must show the district was narrowly tailored to serve a compelling governmental interest, typically compliance with the Voting Rights Act.