Shaw v. Reno (1993) is associated with which principle concerning race-based districting?

• A. Applied strict scrutiny to race-based districting plans
• B. Allowed race-based plans without scrutiny
• C. Disregarded race in drawing districts
• D. Supported partisan advantage in redistricting

Answer: (A)

Race-based districting is subject to strict scrutiny when race is used as a primary factor in drawing legislative boundaries. Shaw v. Reno (1993) clarified that while race can be considered, it cannot be the predominant criterion without careful justification. The Court struck down a North Carolina district that was oddly shaped and appeared drawn largely on racial lines, holding that such plans must be tested under strict scrutiny under the Equal Protection Clause. Under strict scrutiny, the state must show a compelling interest for the racial classification and that the plan is narrowly tailored to achieve that interest, using the least restrictive means. In practice, this means race cannot be the main driver of boundary lines merely to achieve political or racial aims; there must be a strong, non-racial justification, often linked to remedies under the Voting Rights Act. Therefore, this principle is about applying strict scrutiny to race-based districting plans. The decision did not permit race-based plans without scrutiny, it did not ignore race, and it did not endorse partisan advantage in redistricting.