began implementing new ways to bar African Americans from voting. Some of these methods included poll taxes, which many could not afford, literacy tests, that many could not pass, and grandfather clauses, which stated that one can only vote if their grandfather voted. This changed with the passing of the Voting Rights Act of 1965, which outlawed these racially discriminatory practices and required government supervision for states that had less than 50 percent of non-White citizens registered to vote. If any state wanted to change any voting rules, they had to receive pre-clearance to ensure no new rule was racist. The Voting Rights Act prohibited many of the tactics that hindered Black voters from getting their voices heard. This was due to the establishment of the Fourteenth Amendment, which granted citizenship and equal rights to all African-Americans. The law of redistricting had to comply with this act in order for the minority group to have impact in the U.S. government. In addition, any affected American citizen that felt that they are being affected by the Voting Rights Act can file a lawsuit stating that it violates Section 2 of the Voting Rights Act which led rise to the case. However, racial gerrymandering continued past 1965 because it is extremely difficult to prove if districts were drawn on the basis of racial discrimination. This was apparent in the Thornburgh V. Gingles case of 1986 in which Black citizens of North Carolina argued that all white-majority districts were drawn up so a Black representative wouldn't get elected. In this unanimous decision, it was decided that districts did indeed dilute Black votes and therefore did violate the Voting Rights Act. Case Background Janet Reno (appellant) was the 78th Attorney General. She was the first female US Attorney General, selected by President Clinton. Ruth O. Shaw (appellee) was a white Democratic resident of the 12th district in North Carolina. 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. This district would be North Carolina's second "majority-minority" district of majority Black voters. The North Carolina General Assembly submitted the plan to the U.S. Attorney General for preclearance under the Voting Rights Act, but it was rejected by the US Department of Justice which was led by Attorney General Janet Reno. Attorney