sion authored by Sandra Day O’Connor, ultimately
held that the district was illegal, as it did not survive
the “strict scrutiny” analysis, which holds that the
questioned legislation must serve a “compelling gov-
ernment interest,” be “narrowly tailored,” and be
the “least restrictive means” of accomplishing this
goal.
The majority consisted of Chief Justice William
H. Rehnquist and Justices O’Connor, Antonin
Scalia, Clarence Thomas, and Anthony Kennedy.
The Court held that as race was involved, the equal
protection clause came into play. The Court also
held that the district had a “bizarre shape”—making
it likely that the only purpose of the district was a ra-
cial one. The Court then remanded the issue to a
lower court to apply the strict scrutiny test.
The dissenters, consisting of Justices Harry A.
Blackmun, David Souter, John Paul Stevens, and By-
ron White, argued that this case was different from
other racial ones, as a racially weighted district did
not deny anyone else his or her rights and that using
the strict scrutiny test only in districts that favored
minorities resulted in policies disfavoring minorities
overall. The dissent essentially argued that since no
one was harmed, the lawsuit should not have been
allowed. The majority held, however, that a harm
was done to the political body as a whole. It was also
noted by the dissent that whites, not blacks, were the
ones arguing in favor of reversing the district.
Impact In 2001, after four more trips to the Su-
preme Court, a redrawn district (but still a black-
majority one) was allowed. This shift was the result
of two significant differences: First, evidence was
the basis of the 2001 decision and the testing was
against an evidentiary standard; and second, Justice
O’Connor moved her vote from against the district
to in favor of it.
TheShaw v. Renodecision still holds legal signifi-
cance, and it puts a high bar in front of states who
wish to create districts on racial grounds. It thus
makes it difficult for a state to attempt to ensure mi-
nority representation in legislatures.
Further Reading
Canon, David T.Race, Redistricting, and Representa-
tion: The Unintended Consequences of Black Majority
Districts. Chicago: University of Chicago Press,
1999.
Darling, Marsha J. Tyson, ed.Race, Voting, Redis-
tricting, and the Constitution: Sources and Explora-
tions on the Fifteenth Amendment. New York: Rout-
ledge, 2001.
Yarbrough, Tinsley E. Race and Redistricting: The
Shaw-Cromartie Cases. Lawrence: University Press
of Kansas, 2002.
Scott A. MerrimanSee also African Americans; Elections in the
United States, midterm; Elections in the United
States, 1996; Reno, Janet; Supreme Court decisions. Sheehy, Gail
Identification American journalist and lecturer
Born November 27, 1937; Mamaroneck, New
York
Sheehy is best known for her books on life stages. A number
of her books covering passages through life were published
in the 1990’s.
Considered a landmark work, Gail Sheehy’sPas-
sages: Predictable Crises of Adult Life, published in 1976,
remained onThe New York Timesbest-seller list for
more than three years and was translated in a num-
ber of languages. The Library of Congress noted it as
one of the ten most influential books of the time. In
the 1990’s, Sheehy published “Passages” books as
well as biographies.
The Passages series includedThe Silent Passage:
Menopause(1992),New Passages: Mapping Your Life
Across Time(1995), andUnderstanding Men’s Passages:
Discovering the New Map of Men’s Lives(1998).New
Passagestook into account the impact of history on
persons in young adulthood and in later life stages.
The theme of passages in Sheehy’s books has been
controversial, as many social scientists have con-
cluded that most persons do not go through life
stages.
Sheehy published two biographies in the 1990’s,
The Man Who Changed the World: The Lives of Mikhail S.
Gorbachev(1990) andHillar y’s Choice(1999). Her
writings about Hillary Rodham Clinton also stirred
controversy. Following an interview with Clinton for
a 1992Vanity Fairarticle, Sheehy published com-
ments by Clinton that were off-the-record.Hillar y’s
Choicewas said to have factual errors. Nevertheless,
among other awards, Sheehy is a seven-time recipi-
ent of the New York Newswomen’s Club Front Page
Award for distinguished journalism.768 Sheehy, Gail The Nineties in America