Shaw v. Reno, 509 U.S. 630 (1993), was a landmark United States Supreme Court case in the area of redistricting and racial gerrymandering. After the 1990 census, North Carolina qualified to have a 12th district and drew it in a distinct snake-like manner in order to create a “majority-minority” Black district. From there, Ruth O. Shaw sued this proposed plan with the argument that this 12th district was unconstitutional and violated the Fourteenth Amendment under the clause of equal protection. In contrast, Reno, the Attorney General, argued that the district would allow for minority groups to have a voice in elections. In the decision, the court ruled in a 5–4 majority that redistricting based on race must be held to a standard of strict scrutiny under the equal protection clause and on the basis that it violated the fourteenth Amendment because it was drawn solely based on race. Shaw v. Reno was an influential case and received backlash. Some southern states filed against majority-Black districts. This decision played a role in deciding many future cases, including Bush v. Vera and Miller v. Johnson. However, the phrasing of irregularly drawn districts has left room for much interpretation, letting judges use their opinions rather than relying on Shaw. History Gerrymandering To contextualize the Shaw supreme court case, gerrymandering is the redrawing of electoral districts to help give a political advantage. Through this process, political parties can draw the boundaries of districts to favor their party's candidate as they allow for extra seats to be won. The census marks when states can redraw their congressional district lines and in accordance with the Voting Rights Act of 1965, districts must be redrawn equally populated. With new technology and tactics of packing and cracking, gerrymandering has become easier through the years but within gerrymandering, limitations exist. Gerrymandering has come before the Supreme Court in multiple cases but in Shaw, racial gerrymandering refers to Section 2 of the Voting Rights Act. Section 2 of this act opposes using discriminatory voting practices in the election process and that in itself prohibits gerrymandering based on race. Racial Background In 1870, following the Civil war and the abolishment of slavery, the 15th amendment was passed, giving all United States citizens the right to vote regardless of race, color, or previous conditions of servitude. This amendment ensured the voting rights of African Americans. However, after its enactment, many southern states