The U.S. Supreme Court case Ruth O. Shaw, et al. v. Janet Reno, Attorney General, et al., 1992 revolved around the constitutionality of racially gerrymandered districts in North Carolina created after the 1990 census under the Voting Rights Act to increase minority representation in Congress. The plaintiffs argued that this was a violation of their Fourteenth Amendment rights by segregating voters based on race and diluting their voting power. In a narrow decision (5-4), the court ruled that claims of racial gerrymandering could be adjudicated and were subject to strict scrutiny under Equal Protection Clause if it could be proven that race was predominant factor influencing redistricting decisions over traditional districting principles such as compactness or contiguity. However, they did not rule whether these specific districts were unconstitutional but remanded back for further proceedings with new standards set forth by them for determining when racial considerations predominate in redistricting.

In the dissenting opinion for Shaw v. Reno, Justice White argued that the majority's decision was inconsistent with previous rulings on racial gerrymandering and could potentially undermine efforts to ensure minority representation in politics. He contended that there is no constitutional problem with a state intentionally creating a majority-minority district if it does so to comply with the Voting Rights Act or rectify past discrimination. Furthermore, he asserted that such districts do not always lead to political segregation along racial lines as many white voters also support minority candidates in these areas. In his view, this case did not present any unique circumstances warranting judicial intervention; rather, it should have been left up to North Carolina’s citizens and their elected representatives who are more familiar with local conditions than federal judges.