Stricty Scrutiny

Racial gerrymandering was first used as a way to avoid implementing the Fifteenth Amendment and therefore continue racial discrimination in the South after the Civil War. In 1876 the Supreme Court made a decision that was a major setback to the citizenship rights of A

In Shaw v Hunt, the Court again considered the equal protection challenge to North Carolina’s redistricting plan, which created two majority-black districts. Keeping Shaw v. Reno in mind, the district court upheld the constitutionality of the plan, finding that it was narrowly tailored to further the compelling interest of complying with sections of the Voting Rights Act. The Supreme Court reversed the lower court decision, holding that the plan was not narrowly tailored to further a compelling state interest. The Court assumed, but did not decide, that compliance with the Voting Rights Act could be a compelling state interest. However, the Court held that to be narrowly tailored the action must remedy the anticipated violation. In this case, the Court found that the district could not remedy a potential violation of the Voting Rights Act because the district did not contain a geographically compact population.

frican Americans. In U.S. v. Reese the Court held that the 15th amendment did not guarantee any person the right to vote and that states had the sole power to give voting rights to individuals.

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