Shaw V Reno Quotes

simpler approach is to simply examine the designs of the districts. As Justice O’Connor observed in Shaw v. Reno, when it comes to redistricting, looks matter. This approach is especially appropriate in states in which one party has a substantial advantage, for example, the challenge to Maryland’s decision to eliminate one of its two Republican districts as challenged in Lamone v. Benisek.110 The approach may also be more reliable than some that rely on statistical analyses when there are few districts. Wang and his colleagues suggest this approach for states with two to six districts.111 However, some partisan gerrymanders do not have extraordinary-looking districts and some strange shapes result from concerns about something other than party, such as in Maryland where figure 4.3 shows how lines were drawn to maintain two majority-black districts.

In Shaw v. Reno, Justice Sandra Day O’Connor emphasized her concern about the shape of North Carolina’s 12th District. This long, skinny I-85 District, as shown in figure 3.2, stretched across 160 miles of the Carolina Piedmont and seemed on its face to violate the notions of compactness. Justice O’Connor observed, “We believe that reapportionment