Redistricting

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See this article for information about redistricting after the 2020 census.

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Redistricting after the 2020 census

The 2020 cycle
Congressional apportionment
Redistricting before 2024 elections
Redistricting committees
Deadlines
Lawsuits
Timeline of redistricting maps
2022 House elections with multiple incumbents
New U.S.House districts created after apportionment
Congressional maps
State legislative maps
General information
State-by-state redistricting procedures
United States census, 2020
Majority-minority districts
Gerrymandering
Ballotpedia's election legislation tracker

Redistricting is the process of enacting new district boundaries for elected offices, particularly for offices in the U.S. House of Representatives and state legislatures.

All United States Representatives and state legislators are elected from political divisions called districts. The states redraw district lines every 10 years following completion of the United States census. The federal government requires that districts must have nearly equal populations and must not discriminate on the basis of race or ethnicity.[1]

This article provides a broad overview of redistricting. See the sections below for more on the following topics:

  1. Background: This section summarizes federal and state-level requirements for redistricting at both the congressional and state legislative levels. It also includes information about gerrymandering and recent court decisions impacting redistricting processes.
  2. Who's in charge of redistricting?: This section identifies what branch of government or type of organization has final authority over redistricting in each state.
  3. Redistricting and electoral competitiveness: This section summarizes arguments and data about the effect of redistricting on electoral competitiveness.
  4. Majority-minority districts: This section summarizes the legal basis for the creation of majority-minority districts and arguments about the practice.

Background

This section includes background information on federal requirements for congressional redistricting, state legislative redistricting, state-based requirements, redistricting methods used in the 50 states, gerrymandering, and recent court decisions.

Federal requirements for congressional redistricting

According to Article I, Section 4 of the United States Constitution, the states and their legislatures have primary authority in determining the "times, places, and manner" of congressional elections. Congress may also pass laws regulating congressional elections.[2][3]

The Times, Places and Manner of holding Elections for Senators and Representatives, shall be prescribed in each State by the Legislature thereof; but the Congress may at any time by Law make or alter such Regulations, except as to the Places of chusing Senators.[4]
—United States Constitution

Article I, Section 2 of the United States Constitution stipulates that congressional representatives be apportioned to the states on the basis of population. There are 435 seats in the United States House of Representatives. Each state is allotted a portion of these seats based on the size of its population relative to the other states. Consequently, a state may gain seats in the House if its population grows or lose seats if its population decreases, relative to populations in other states. In 1964, the United States Supreme Court ruled in Wesberry v. Sanders that the populations of House districts must be equal "as nearly as practicable."[5][6][7]

The equal population requirement for congressional districts is strict. According to All About Redistricting, "Any district with more or fewer people than the average (also known as the 'ideal' population), must be specifically justified by a consistent state policy. And even consistent policies that cause a 1 percent spread from largest to smallest district will likely be unconstitutional."[7]

Federal requirements for state legislative redistricting

The United States Constitution is silent on the issue of state legislative redistricting. In the mid-1960s, the United States Supreme Court issued a series of rulings in an effort to clarify standards for state legislative redistricting. In Reynolds v. Sims, the court ruled that "the Equal Protection Clause [of the United States Constitution] demands no less than substantially equal state legislative representation for all citizens, of all places as well as of all races." According to All About Redistricting, "it has become accepted that a [redistricting] plan will be constitutionally suspect if the largest and smallest districts [within a state or jurisdiction] are more than 10 percent apart."[7]

State-based requirements

In addition to the federal criteria noted above, individual states may impose additional requirements on redistricting. Common state-level redistricting criteria are listed below.

  1. Contiguity refers to the principle that all areas within a district should be physically adjacent. A total of 49 states require that districts of at least one state legislative chamber be contiguous (Nevada has no such requirement, imposing no requirements on redistricting beyond those enforced at the federal level). A total of 23 states require that congressional districts meet contiguity requirements.[7][8]
  2. Compactness refers to the general principle that the constituents within a district should live as near to one another as practicable. A total of 37 states impose compactness requirements on state legislative districts; 18 states impose similar requirements for congressional districts.[7][8]
  3. A community of interest is defined by FairVote as a "group of people in a geographical area, such as a specific region or neighborhood, who have common political, social or economic interests." A total of 24 states require that the maintenance of communities of interest be considered in the drawing of state legislative districts. A total of 13 states impose similar requirements for congressional districts.[7][8]
  4. A total of 42 states require that state legislative district lines be drawn to account for political boundaries (e.g., the limits of counties, cities, and towns). A total of 19 states require that similar considerations be made in the drawing of congressional districts.[7][8]

Methods

In general, a state's redistricting authority can be classified as one of the following:[9]

  1. Legislature-dominant: In a legislature-dominant state, the legislature retains the ultimate authority to draft and enact district maps. Maps enacted by the legislature may or may not be subject to gubernatorial veto. Advisory commissions may also be involved in the redistricting process, although the legislature is not bound to adopt an advisory commission's recommendations.
  2. Commission: In a commission state, an extra-legislative commission retains the ultimate authority to draft and enact district maps. A non-politician commission is one whose members cannot hold elective office. A politician commission is one whose members can hold elective office.
  3. Hybrid: In a hybrid state, the legislature shares redistricting authority with a commission.

Gerrymandering

In 1812, Massachusetts Governor Elbridge Gerry signed into law a state Senate district map that, according to the Encyclopædia Britannica, "consolidated the Federalist Party vote in a few districts and thus gave disproportionate representation to Democratic-Republicans." The word gerrymander was coined by The Boston Gazette to describe the district.
See also: Gerrymandering

The term gerrymandering refers to the practice of drawing electoral district lines to favor one political party, individual, or constituency over another. When used in a rhetorical manner by opponents of a particular district map, the term has a negative connotation but does not necessarily address the legality of a challenged map. The term can also be used in legal documents; in this context, the term describes redistricting practices that violate federal or state laws.[1][10]

For additional background information about gerrymandering, click "[Show more]" below.

Show more

The phrase racial gerrymandering refers to the practice of drawing electoral district lines to dilute the voting power of racial minority groups. Federal law prohibits racial gerrymandering and establishes that, to combat this practice and to ensure compliance with the Voting Rights Act, states and jurisdictions can create majority-minority electoral districts. A majority-minority district is one in which a racial group or groups comprise a majority of the district's populations. Racial gerrymandering and majority-minority districts are discussed in greater detail in this article.[11]

The phrase partisan gerrymandering refers to the practice of drawing electoral district maps with the intention of favoring one political party over another. In contrast with racial gerrymandering, on which the Supreme Court of the United States has issued rulings in the past affirming that such practices violate federal law, the high court had not, as of November 2017, issued a ruling establishing clear precedent on the question of partisan gerrymandering. Although the court has granted in past cases that partisan gerrymandering can violate the United States Constitution, it has never adopted a standard for identifying or measuring partisan gerrymanders. Partisan gerrymandering is described in greater detail in this article.[12][13]

Recent court decisions

See also: Redistricting cases heard by the Supreme Court of the United States

The Supreme Court of the United States has, in recent years, issued several decisions dealing with redistricting policy, including rulings relating to the consideration of race in drawing district maps, the use of total population tallies in apportionment, and the constitutionality of independent redistricting commissions. The rulings in these cases, which originated in a variety of states, impact redistricting processes across the nation.

For additional background information about these cases, click "[Show more]" below.

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Alexander v. South Carolina State Conference of the NAACP (2024)

See also: Alexander v. South Carolina State Conference of the NAACP

Alexander v. South Carolina State Conference of the NAACP — This case concerns a challenge to the congressional redistricting plan that the South Carolina legislature enacted after the 2020 census. In January 2023, a federal three-judge panel ruled that the state's 1st Congressional District was unconstitutional and enjoined the state from conducting future elections using its district boundaries. The panel's opinion said, "The Court finds that race was the predominant factor motivating the General Assembly’s adoption of Congressional District No. 1...Defendants have made no showing that they had a compelling state interest in the use of race in the design of Congressional District No. 1 and thus cannot survive a strict scrutiny review."[14] Thomas Alexander (R)—in his capacity as South Carolina State Senate president—appealed the federal court's ruling, arguing: :In striking down an isolated portion of South Carolina Congressional District 1 as a racial gerrymander, the panel never even mentioned the presumption of the General Assembly’s “good faith.”...The result is a thinly reasoned order that presumes bad faith, erroneously equates the purported racial effect of a single line in Charleston County with racial predominance across District 1, and is riddled with “legal mistake[s]” that improperly relieved Plaintiffs of their “demanding” burden to prove that race was the “predominant consideration” in District 1.[15] The U.S. Supreme Court scheduled oral argument on this case for October 11, 2023.[16]

Moore v. Harper (2023)

See also: Moore v. Harper

At issue in Moore v. Harper, was whether state legislatures alone are empowered by the Constitution to regulate federal elections without oversight from state courts, which is known as the independent state legislature doctrine. On November 4, 2021, the North Carolina General Assembly adopted a new congressional voting map based on 2020 Census data. The legislature, at that time, was controlled by the Republican Party. In the case Harper v. Hall (2022), a group of Democratic Party-affiliated voters and nonprofit organizations challenged the map in state court, alleging that the new map was a partisan gerrymander that violated the state constitution.[17] On February 14, 2022, the North Carolina Supreme Court ruled that the state could not use the map in the 2022 elections and remanded the case to the trial court for further proceedings. The trial court adopted a new congressional map drawn by three court-appointed experts. The United States Supreme Court affirmed the North Carolina Supreme Court's original decision in Moore v. Harper that the state's congressional district map violated state law. In a 6-3 decision, Chief Justice John Roberts wrote that the "Elections Clause does not vest exclusive and independent authority in state legislatures to set the rules regarding federal elections.[18]

Merrill v. Milligan (2023)

See also: Merrill v. Milligan

At issue in Merrill v. Milligan, was the constitutionality of Alabama's 2021 redistricting plan and whether it violated Section 2 of the Voting Rights Act. A group of Alabama voters and organizations sued Secretary of State John Merrill (R) and the House and Senate redistricting chairmen, Rep. Chris Pringle (R) and Sen. Jim McClendon (R). Plaintiffs alleged the congressional map enacted on Nov. 4, 2021, by Gov. Kay Ivey (R) unfairly distributed Black voters. The plaintiffs asked the lower court to invalidate the enacted congressional map and order a new map with instructions to include a second majority-Black district. The court ruled 5-4, affirming the lower court opinion that the plaintiffs showed a reasonable likelihood of success concerning their claim that Alabama's redistricting map violated Section 2 of the Voting Rights Act.[19]

Gill v. Whitford (2018)

See also: Gill v. Whitford

In Gill v. Whitford, decided on June 18, 2018, the Supreme Court of the United States ruled that the plaintiffs—12 Wisconsin Democrats who alleged that Wisconsin's state legislative district plan had been subject to an unconstitutional gerrymander in violation of the First and Fourteenth Amendments—had failed to demonstrate standing under Article III of the United States Constitution to bring a complaint. The court's opinion, penned by Chief Justice John Roberts, did not address the broader question of whether partisan gerrymandering claims are justiciable and remanded the case to the district court for further proceedings. Roberts was joined in the majority opinion by Associate Justices Anthony Kennedy, Ruth Bader Ginsburg, Stephen Breyer, Samuel Alito, Sonia Sotomayor, and Elena Kagan. Kagan penned a concurring opinion joined by Ginsburg, Breyer, and Sotomayor. Associate Justice Clarence Thomas penned an opinion that concurred in part with the majority opinion and in the judgment, joined by Associate Justice Neil Gorsuch.[20]

Cooper v. Harris (2017)

See also: Cooper v. Harris

In Cooper v. Harris, decided on May 22, 2017, the Supreme Court of the United States affirmed the judgment of the United States District Court for the Middle District of North Carolina, finding that two of North Carolina's congressional districts, the boundaries of which had been set following the 2010 United States Census, had been subject to an illegal racial gerrymander in violation of Section 2 of the Voting Rights Act. Justice Elena Kagan delivered the court's majority opinion, which was joined by Justices Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer, and Sonia Sotomayor (Thomas also filed a separate concurring opinion). In the court's majority opinion, Kagan described the two-part analysis utilized by the high court when plaintiffs allege racial gerrymandering as follows: "First, the plaintiff must prove that 'race was the predominant factor motivating the legislature's decision to place a significant number of voters within or without a particular district.' ... Second, if racial considerations predominated over others, the design of the district must withstand strict scrutiny. The burden shifts to the State to prove that its race-based sorting of voters serves a 'compelling interest' and is 'narrowly tailored' to that end." In regard to the first part of the aforementioned analysis, Kagan went on to note that "a plaintiff succeeds at this stage even if the evidence reveals that a legislature elevated race to the predominant criterion in order to advance other goals, including political ones." Justice Samuel Alito delivered an opinion that concurred in part and dissented in part with the majority opinion. This opinion was joined by Chief Justice John Roberts and Justice Anthony Kennedy.[21][22][23]

Evenwel v. Abbott (2016)

See also: Evenwel v. Abbott

Evenwel v. Abbott was a case decided by the Supreme Court of the United States in 2016. At issue was the constitutionality of state legislative districts in Texas. The plaintiffs, Sue Evenwel and Edward Pfenninger, argued that district populations ought to take into account only the number of registered or eligible voters residing within those districts as opposed to total population counts, which are generally used for redistricting purposes. Total population tallies include non-voting residents, such as immigrants residing in the country without legal permission, prisoners, and children. The plaintiffs alleged that this tabulation method dilutes the voting power of citizens residing in districts that are home to smaller concentrations of non-voting residents. The court ruled 8-0 on April 4, 2016, that a state or locality can use total population counts for redistricting purposes. The majority opinion was penned by Justice Ruth Bader Ginsburg.[24][25][26][27]

Harris v. Arizona Independent Redistricting Commission (2016)

Justice Stephen Breyer penned the majority opinion in Harris v. Arizona Independent Redistricting Commission.
See also: Harris v. Arizona Independent Redistricting Commission

Harris v. Arizona Independent Redistricting Commission was a case decided by the Supreme Court of the United States in 2016. At issue was the constitutionality of state legislative districts that were created by the commission in 2012. The plaintiffs, a group of Republican voters, alleged that "the commission diluted or inflated the votes of almost two million Arizona citizens when the commission intentionally and systematically overpopulated 16 Republican districts while under-populating 11 Democrat districts." This, the plaintiffs argued, constituted a partisan gerrymander. The plaintiffs claimed that the commission placed a disproportionately large number of non-minority voters in districts dominated by Republicans; meanwhile, the commission allegedly placed many minority voters in smaller districts that tended to vote Democratic. As a result, the plaintiffs argued, more voters overall were placed in districts favoring Republicans than in those favoring Democrats, thereby diluting the votes of citizens in the Republican-dominated districts. The defendants countered that the population deviations resulted from legally defensible efforts to comply with the Voting Rights Act and obtain approval from the United States Department of Justice. At the time of redistricting, certain states were required to obtain preclearance from the U.S. Department of Justice before adopting redistricting plans or making other changes to their election laws—a requirement struck down by the United States Supreme Court in Shelby County v. Holder (2013). On April 20, 2016, the court ruled unanimously that the plaintiffs had failed to prove that a partisan gerrymander had taken place. Instead, the court found that the commission had acted in good faith to comply with the Voting Rights Act. The court's majority opinion was penned by Justice Stephen Breyer.[28][29][30]

Arizona State Legislature v. Arizona Independent Redistricting Commission (2015)

See also: Arizona State Legislature v. Arizona Independent Redistricting Commission
Arizona State Legislature v. Arizona Independent Redistricting Commission was a case decided by the Supreme Court of the United States in 2015. At issue was the constitutionality of the Arizona Independent Redistricting Commission, which was established by state constitutional amendment in 2000. According to Article I, Section 4 of the United States Constitution, "the Times, Places and Manner of holding Elections for Senators and Representatives shall be prescribed in each State by the Legislature thereof." The state legislature argued that the use of the word "legislature" in this context is literal; therefore, only a state legislature may draw congressional district lines. Meanwhile, the commission contended that the word "legislature" ought to be interpreted to mean "the legislative powers of the state," including voter initiatives and referenda. On June 29, 2015, the court ruled 5-4 in favor of the Arizona Independent Redistricting Commission, finding that "redistricting is a legislative function, to be performed in accordance with the state's prescriptions for lawmaking, which may include the referendum and the governor's veto." The majority opinion was penned by Justice Ruth Bader Ginsburg and joined by Justices Anthony Kennedy, Stephen Breyer, Elena Kagan, and Sonia Sotomayor. Chief Justice John Roberts and Justices Clarence Thomas, Antonin Scalia, and Samuel Alito dissented.[31][32][33][34]

Redistricting information by state

Select a state on the map below to read more about redistricting in that state.

http://ballotpedia.org/Redistricting_in_STATE

Who's in charge of redistricting?

Congressional redistricting

Most states are required to draw new congressional district lines every 10 years following completion of United States Census (those states comprising one congressional district are not required to redistrict). In 33 of these states, state legislatures play the dominant role in congressional redistricting. In nine states, commissions draw congressional district lines. In two states, hybrid systems are used, in which the legislatures share redistricting authority with commissions. The remaining states comprise one congressional district each, rendering redistricting unnecessary. See the map and table below for further details.[35][36]

State legislative redistricting

In 33 of the 50 states, state legislatures play the dominant role in state legislative redistricting. Commissions draw state legislative district lines in 14 states. In three states, hybrid systems are used, in which state legislature share redistricting authority with commissions. See the map and table below for further details.[35]

Redistricting and electoral competitiveness

There are conflicting opinions regarding the correlation between partisan gerrymandering and electoral competitiveness. In 2012, Jennifer Clark, a political science professor at the University of Houston, said, "The redistricting process has important consequences for voters. In some states, incumbent legislators work together to protect their own seats, which produces less competition in the political system. Voters may feel as though they do not have a meaningful alternative to the incumbent legislator. Legislators who lack competition in their districts have less incentive to adhere to their constituents’ opinions."[37]

In 2006, Emory University professor Alan Abramowitz and Ph.D. students Brad Alexander and Matthew Gunning wrote, "[Some] studies have concluded that redistricting has a neutral or positive effect on competition. ... [It] is often the case that partisan redistricting has the effect of reducing the safety of incumbents, thereby making elections more competitive."[38]

In 2011, James Cottrill, a professor of political science at Santa Clara University, published a study of the effect of non-legislative approaches (e.g., independent commissions, politician commissions) to redistricting on the competitiveness of congressional elections. Cottrill found that "particular types of [non-legislative approaches] encourage the appearance in congressional elections of experienced and well-financed challengers." Cottrill cautioned, however, that non-legislative approaches "contribute neither to decreased vote percentages when incumbents win elections nor to a greater probability of their defeat."[39]

In 2021, John Johnson, Research Fellow in the Lubar Center for Public Policy Research and Civic Education at Marquette University, reviewed the relationship between partisan gerrymandering and political geography in Wisconsin, a state where Republicans have controlled both chambers of the state legislature since 2010 while voting for the Democratic nominee in every presidential election but one since 1988. After analyzing state election results since 2000, Johnson wrote, "In 2000, 42% of Democrats and 36% of Republicans lived in a neighborhood that the other party won. Twenty years later, 43% of Democrats lived in a place Trump won, but just 28% of Republicans lived in a Biden-voting neighborhood. Today, Democrats are more likely than Republicans to live in both places where they are the overwhelming majority and places where they form a noncompetitive minority."[40]

Majority-minority districts

Section 2 of the Voting Rights Act of 1965 mandates that electoral district lines cannot be drawn in such a manner as to "improperly dilute minorities' voting power."[41]

No voting qualification or prerequisite to voting, or standard, practice, or procedure shall be imposed or applied by any State or political subdivision to deny or abridge the right of any citizen of the United States to vote on account of race or color.[4]
—Voting Rights Act of 1965[42]

States and other political subdivisions may create majority-minority districts in order to comply with Section 2 of the Voting Rights Act.[43]

Support and opposition

Support

Proponents of majority-minority districts argue that these districts are a necessary hindrance to the practice of cracking, which occurs when a constituency is divided between several districts in order to prevent it from achieving a majority in any one district. In an April 2015 report for the Congressional Research Service, legislative attorney L. Paige Whitaker described this argument as follows:[11]

A majority-minority district is one in which a racial or language minority group comprises a voting majority. The creation of such districts can avoid racial vote dilution by preventing the submergence of minority voters into the majority, which can deny minority voters the opportunity to elect a candidate of their choice.[4]
—L. Paige Whitaker

In addition, supporters argue that the drawing of majority-minority districts has resulted in an increased number of minority representatives in state legislatures and Congress. The American Civil Liberties Union, in a 2001 report, made this argument:[44][45][46][47]

In 1964, there were only about 300 black elected officials nationwide. By 1998 the number had grown to more than 8,858. This increase is the direct result of the increase in majority-minority districts since passage of the Voting Rights Act in 1965. ... Given the persistent patterns of racial bloc voting in the South, the destruction of majority-minority districts, whether at the congressional or state and local levels, would inevitable lead to a decline in the number of minority office holders.[4]
American Civil Liberties Union

Opposition

Critics, meanwhile, contend that the establishment of majority-minority districts can result in packing, which occurs when a constituency or voting group is placed within a single district, thereby minimizing its influence in other districts. Kim Soffen, writing for The Washington Post in June 2016, summarized this argument as follows:[48]

Imagine the minority-favored candidate can win an election in a district if at least 30 percent of voters are minorities. What harm is done by the legislators packing the district up to 50 percent minority voters? Much like political gerrymandering, it limits black influence in surrounding districts. It would require the creation of, for instance, a 50 percent and a 10 percent black district, rather than two 30 percent black districts. In other words, the requirement would give black voters one representative of their choice rather than two.[4]
—Kim Soffen

Because minority groups tend to vote Democratic, critics argue that majority-minority districts ultimately present an unfair advantage to Republicans by consolidating Democratic votes into a smaller number of districts. Steven Hill, writing for The Atlantic in June 2013, made the following argument:[44][45][46]

The drawing of majority-minority districts not only elected more minorities, it also had the effect of bleeding minority voters out of all the surrounding districts. Given that minority voters were the most reliably Democratic voters, that made all of the neighboring districts more Republican. The black, Latino, and Asian representatives mostly were replacing white Democrats, and the increase in minority representation was coming at the expense of electing fewer Democrats.[4]
—Steven Hill

Recent news

The link below is to the most recent stories in a Google news search for the terms Redistricting. These results are automatically generated from Google. Ballotpedia does not curate or endorse these articles.

See also

External links

Footnotes

  1. 1.0 1.1 All About Redistricting, "Why does it matter?" accessed April 8, 2015
  2. The Heritage Guide to the Constitution, "Election Regulations," accessed April 13, 2015
  3. Brookings, "Redistricting and the United States Constitution," March 22, 2011
  4. 4.0 4.1 4.2 4.3 4.4 4.5 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
  5. Brennan Center for Justice, "A Citizen's Guide to Redistricting," accessed March 25, 2015
  6. The Constitution of the United States of America, "Article 1, Section 2," accessed March 25, 2015
  7. 7.0 7.1 7.2 7.3 7.4 7.5 7.6 All About Redistricting, "Where are the lines drawn?" accessed April 9, 2015
  8. 8.0 8.1 8.2 8.3 FairVote, "Redistricting Glossary," accessed April 9, 2015
  9. All About Redistricting, "Who draws the lines?" accessed June 19, 2017
  10. Encyclopædia Britannica, "Gerrymandering," November 4, 2014
  11. 11.0 11.1 Congressional Research Service, "Congressional Redistricting and the Voting Rights Act: A Legal Overview," April 13, 2015
  12. The Wall Street Journal, "Supreme Court to Consider Limits on Partisan Drawing of Election Maps," June 19, 2017
  13. The Washington Post, "Supreme Court to hear potentially landmark case on partisan gerrymandering," June 19, 2017
  14. United States District Court for the District of South Carolina, Columbia Division, "South Carolina State Conference of the NAACP, et al. v. Alexander," January 6, 2023
  15. Supreme Court of the United States, "Alexander, et al. v. The South Carolina State Conference of the NAACP, et al.," February 17, 2023
  16. SCOTUSblog, "Alexander v. South Carolina State Conference of the NAACP," accessed July 21, 2023
  17. SCOTUSblog, "Justices will hear case that tests power of state legislatures to set rules for federal elections," June 30, 2022
  18. U.S. Supreme Court, “Moore, in his Official Capacity as Speaker of The North Carolina House of Representatives, et al. v. Harper et al.," "Certiorari to the Supreme Court of North Carolina,” accessed June 16, 2023
  19. SCOTUSblog.org, "Supreme Court upholds Section 2 of Voting Rights Act," June 8, 2023
  20. Supreme Court of the United States, "Gill v. Whitford: Decision," June 18, 2018
  21. Election Law Blog, "Breaking: SCOTUS to Hear NC Racial Gerrymandering Case," accessed June 27, 2016
  22. Ballot Access News, "U.S. Supreme Court Accepts Another Racial Gerrymandering Case," accessed June 28, 2016
  23. Supreme Court of the United States, "Cooper v. Harris: Decision," May 22, 2017
  24. The Washington Post, "Supreme Court to hear challenge to Texas redistricting plan," May 26, 2015
  25. The New York Times, "Supreme Court Agrees to Settle Meaning of ‘One Person One Vote,'" May 26, 2015
  26. SCOTUSblog, "Evenwel v. Abbott," accessed May 27, 2015
  27. Associated Press, "Supreme Court to hear Texas Senate districts case," May 26, 2015
  28. SCOTUSblog, "The new look at 'one person, one vote,' made simple," July 27, 2015
  29. Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission: Brief for Appellants," accessed December 14, 2015
  30. Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission," April 20, 2016
  31. The New York Times, "Court Skeptical of Arizona Plan for Less-Partisan Congressional Redistricting," March 2, 2015
  32. The Atlantic, "Will the Supreme Court Let Arizona Fight Gerrymandering?" September 15, 2014
  33. United States Supreme Court, "Arizona State Legislature v. Arizona Independent Redistricting Commission: Opinion of the Court," June 29, 2015
  34. The New York Times, "Supreme Court Upholds Creation of Arizona Redistricting Commission," June 29, 2015
  35. 35.0 35.1 All About Redistricting, "Who draws the lines?" accessed March 25, 2015
  36. Brennan Center for Justice, "National Overview of Redistricting: Who draws the lines?" June 1, 2010
  37. The Daily Cougar, "Redistricting will affect November election," October 16, 2012
  38. The Journal of Politics, "Incumbency, Redistricting, and the Decline of Competition in U.S. House Elections," February 2006
  39. Polity, "The Effects of Non-Legislative Approaches to Redistricting on Competition in Congressional Elections," October 3, 2011
  40. Marquette University Law School Faculty Blog, "Why Do Republicans Overperform in the Wisconsin State Assembly? Partisan Gerrymandering Vs. Political Geography," February 11, 2021
  41. Legal Information Institute, "Voting Rights Act," accessed June 19, 2017
  42. Yale Law School, The Avalon Project, "Voting Rights Act of 1965; August 6, 1965," accessed April 6, 2015
  43. Justice.gov, "Section 2 of the Voting Rights Act," accessed July 21, 2015
  44. 44.0 44.1 Indy Week, "Cracked, stacked and packed: Initial redistricting maps met with skepticism and dismay," June 29, 2011
  45. 45.0 45.1 The Atlantic, "How the Voting Rights Act Hurts Democrats and Minorities," June 17, 2013
  46. 46.0 46.1 Redrawing the Lines, "The Role of Section 2 - Majority Minority Districts," accessed April 6, 2015
  47. American Civil LIberties Union, "Everything You Always Wanted to Know About Redistricting," April 2001
  48. The Washington Post, "How racial gerrymandering deprives black people of political power," June 9, 2016