Shaw v. Reno: Race-Predominant Maps Trigger Strict Scrutiny

The Supreme Court ruled 5-4 that North Carolina voters could challenge a majority-Black congressional district under the Equal Protection Clause, even though the district was created to increase Black representation. Justice O'Connor wrote that when race is the predominant factor in drawing district lines, the map triggers strict scrutiny and must survive a compelling-interest analysis. The ruling introduced constitutional limits on race-conscious redistricting done to comply with the VRA.