Applying the Shaw v. Reno Test for Racial Gerrymandering

In 1995, the Supreme Court put their racial gerrymandering test… to the test, with the case Miller v. Johnson. It had been just two years since the landmark Shaw v. Reno decision created a specific requirement for racial gerrymandering rulings: that race cannot be the only discernible explanation for the way districts were drawn.

Miller v. Johnson brought up an important question for this test: does it still apply if the districts were made to maximize minority representation? The court ruled that it does. This solidified the Shaw test, and further clarified the Constitution’s illegalization of racial gerrymandering.