Shaw v. Hunt

Shaw v. Hunt, 517 U.S. 899 (1996), was a United States Supreme Court case concerning redistricting and racial gerrymandering. This case and its predecessor, Shaw v. Reno, concerned North Carolina's congressional redistricting plans. The Court ruled in Shaw v. Hunt that the redistricting plan violated the Equal Protection Clause of the Fourteenth Amendment.

Background
In Shaw v. Reno, the Supreme Court found that the complaint challenging a redistricting plan creating two unusually looking majority-minority congressional districts stated a claim for relief under the Equal Protection Clause, and thus remanded the case. The district court then held that the plan survived strict scrutiny and was constitutional. As a result, the constitutionality of this plan was brought before the Supreme Court again.

Decision
In a 5–4 decision delivered by Justice Rehnquist, the Court held that the redistricting plan violated the Equal Protection Clause. The Court applied strict scrutiny to the plan, concluding that it was not narrowly tailored to serve a compelling state interest. The Court found that none of the three compelling interests identified by the State was sufficient to survive strict scrutiny. For the first stated "interest in eradicating the effects of past discrimination," the Court upheld the district court's finding that this interest did not bring out the use of race in the plan; for the second claimed interest of complying with Section 5 of the Voting Rights Act, the Court found that under a correct reading of the section, creating an additional majority-minority district was not required; for the third interest of avoiding liability under Section 2 of the Voting Rights Act, which prohibited dilution of minorities' voting strength, the Court found that the redistricting plan would not be able to remedy any such violation.

This decision, however, left unanswered the question of whether compliance with the Voting Rights Act would provide a compelling interest for a state to engage in racial gerrymandering.