reapportionment, gerrymandering, Voting Rights Act


The Supreme Court's decision in Shaw V. Reno forbade the drawing of congressional district lines so that minorities would make up a larger percentage of the voting population. This note explores the tension between this ruling and the section of the Voting Rights Act requiring that minorities be fully represented within their congressional districts. It argues that the two rulings do not necessarily conflict. It concludes that the Court should clarify the meaning and role of "compactness" in redistricting and provide guideposts for legislators litigants, and courts involved in the reapportionment process.



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