Redistricting in Rhode Island after the 2020 census

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General information
State-by-state redistricting procedures • Majority-minority districts • Gerrymandering
The 2020 cycle
United States census, 2020 • Congressional apportionment • Redistricting committees • Deadlines • 2022 House elections with multiple incumbents • New U.S.House districts created after apportionment • Congressional maps • State legislative maps • Lawsuits • Status of redistricting after the 2020 census
Redrawn maps
Redistricting before 2024 elections • Redistricting before 2026 elections
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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. This article chronicles the 2020 redistricting cycle in Rhode Island.

Rhode Island enacted new congressional district boundaries on February 16, 2022, when Gov. Dan McKee (D) signed redistricting legislation that the General Assembly had approved the day before. The State House of Representatives passed the district boundaries, 57-6, with 53 Democrats and four Republicans voting in favor and four Republicans and two Democrats voting against. The State Senate approved the new maps 29-9 with all 'yes' votes from Democrats and five Republicans and four Democrats voting 'no.'

Rhode Island enacted new legislative district boundaries on February 16, 2022, when Gov. Dan McKee (D) signed redistricting legislation approved by the General Assembly. The State House of Representatives passed the new maps by a vote of 57-6 and the State Senate approved them, 29-9, on February 15, 2022. In a press release issued after Gov. McKee signed the legislation, State Representative Robert Phillips (D), co-chair of the state's legislative Reapportionment Commission, said, "It was an honor and pleasure to work with such a dedicated group of individuals on this commission. I’m particularly proud of the fact that we obtained so much input from citizens around the state, holding our meetings in several cities and towns to make it more accessible to everyone. Reapportionment can be daunting and complex, but I’m glad we took everyone’s concerns into account and came up with a fair and equitable system of reapportionment.”

Click here for more information.

Rhode Island's two United States representatives and 113 state legislators are all elected from political divisions called districts. District lines are redrawn every 10 years following completion of the United States census. Federal law stipulates that districts must have nearly equal populations and must not discriminate on the basis of race or ethnicity.

See the sections below for further information on the following topics:

1. Summary: This section provides summary information about the drafting and enacting processes.
2. Apportionment and release of census data: This section details the 2020 apportionment process, including data from the United States Census Bureau.
3. Drafting process: This section details the drafting process for new congressional and state legislative district maps.
4. Enactment: This section provides information about the enacted congressional and state legislative district maps.
5. Court challenges: This section details court challenges to the enacted congressional and state legislative district maps.
6. Background: This section summarizes federal and state-based requirements for redistricting at both the congressional and state legislative levels. A summary of the 2010 redistricting cycle in Rhode Island is also provided.

Summary

This section lists major events in the post-2020 census redistricting cycle in reverse chronological order. Major events include the release of apportionment data, the release of census population data, the introduction of formal map proposals, the enactment of new maps, and noteworthy court challenges. Click the dates below for additional information.

• February 16, 2022: Gov. Dan McKee (D) signed legislation redrawing the state's congressional and legislative district boundaries.
• February 15, 2022: The House and Senate passed legislative and congressional maps.
• January 12, 2022: The Special Commission on Reapportionment voted to approve state legislative and congressional maps.
• January 5, 2022: The commission voted 15-1 to approve new guidelines concerning the residency status of prison inmates.
• December 13, 2021: The commission released a third General Assembly map draft.
• December 9, 2021: The commission released a third Senate map draft.
• December 3, 2021: The commission released map proposals for General Assembly districts.
• September 16, 2021: The U.S. Census Bureau released data from the 2020 census in an easier-to-use format to state redistricting authorities and the public.
• September 9, 2021: The Rhode Island General Assembly's Special Commission on Reapportionment held its first meeting.
• August 12, 2021: The U.S. Census Bureau delivered redistricting data to states in a legacy format.
• April 26, 2021: The U.S. Census Bureau delivered apportionment counts.

Enactment

Enacted congressional district maps

See also: Congressional district maps implemented after the 2020 census

Rhode Island enacted new congressional district boundaries on February 16, 2022, when Gov. Dan McKee (D) signed redistricting legislation that the General Assembly had approved the day before. The State House of Representatives passed the district boundaries, 57-6, with 53 Democrats and four Republicans voting in favor and four Republicans and two Democrats voting against. The State Senate approved the new maps 29-9 with all 'yes' votes from Democrats and five Republicans and four Democrats voting 'no.'

Patrick Anderson and Katherine Gregg wrote in The Providence Journal that "ruling Democrats didn't make major map changes to protect the state's Second Congressional District from a GOP takeover attempt, even after incumbent U.S. Rep. Jim Langevin announced he would not run for reelection. In the last redistricting a decade ago, the Assembly shifted tens of thousands of Democratic voters from the second district into the first district, benefitting Rep. David Cicilline, who was facing his first reelection campaign."

Congressional map

Below are the congressional maps in effect before and after the 2020 redistricting cycle.

Rhode Island Congressional Districts
until January 2, 2023

Click a district to compare boundaries.

Rhode Island Congressional Districts
starting January 3, 2023

Click a district to compare boundaries.

Reactions

Rep. Barbara Ann Fenton-Fung (R) praised House Speaker K. Joseph Shekarchi (D) because the plan made minimal changes to congressional district boundaries even though Democrats had majorities in both chambers of the legislature, saying, "I think a lesser person might have played some games and the fact that the bills came through as is says a lot about your leadership in Rhode Island, where we are used to games happening. Senator Jessica de la Cruz (R) objected to the final maps being released just before each chamber voted on them, saying, "There was not ample time for the community to comment on them."

2020 presidential results

The table below details the results of the 2020 presidential election in each district at the time of the 2022 election and its political predecessor district. This data was compiled by Daily Kos Elections.

2020 presidential results by Congressional district, Rhode Island
District	2022 district		Political predecessor district
	Joe Biden	Donald Trump	Joe Biden	Donald Trump
Rhode Island's 1st	63.8%	34.7%	63.9%	34.6%
Rhode Island's 2nd	56.1%	42.4%	56.0%	42.5%

Enacted state legislative district maps

See also: State legislative district maps implemented after the 2020 census

Rhode Island enacted new legislative district boundaries on February 16, 2022, when Gov. Dan McKee (D) signed redistricting legislation approved by the General Assembly. The State House of Representatives passed the new maps by a vote of 57-6 and the State Senate approved them, 29-9, on February 15, 2022. In a press release issued after Gov. McKee signed the legislation, State Representative Robert Phillips (D), co-chair of the state's legislative Reapportionment Commission, said, "It was an honor and pleasure to work with such a dedicated group of individuals on this commission. I’m particularly proud of the fact that we obtained so much input from citizens around the state, holding our meetings in several cities and towns to make it more accessible to everyone. Reapportionment can be daunting and complex, but I’m glad we took everyone’s concerns into account and came up with a fair and equitable system of reapportionment.”

The Providence Journal's Patrick Anderson and Katherine Gregg wrote "Although some district boundaries changed a lot, the new maps did not put any incumbent General Assembly members in the same district, forcing them to run against each other. But the maps did draw some would-be challengers out of their current districts, potentially protecting incumbents from a tough reelection battle. Edward Fitzpatrick of the Boston Globe wrote that "critics have said both Democratic and Republican incumbents were allowed to shape their districts during private meetings with the state’s long-time redistricting consultant."

State Senate map

Below is the state Senate map in effect before and after the 2020 redistricting cycle.

Rhode Island State Senate Districts
until January 2, 2023

Click a district to compare boundaries.

Rhode Island State Senate Districts
starting January 3, 2023

Click a district to compare boundaries.

State House map

Below is the state House map in effect before and after the 2020 redistricting cycle.

Rhode Island State House Districts
until January 2, 2023

Click a district to compare boundaries.

Rhode Island State House Districts
starting January 3, 2023

Click a district to compare boundaries.

Reactions

In a press release issued after the maps were signed, State Sen. Steve Archambault (D), co-chair of the legislative Reapportionment Commission, said, “I’m proud of the work we were able to do in the redistricting commission. We were able to commit to an openness and transparency every step of the way, so that all interested parties could see what was going on at all times. That includes maintaining a web site that made all redistricting plans and census data available to the public and giving everyone access to the software that was used to redraw the maps.” John M. Marion, executive director of Common Cause Rhode Island, criticized the process and final maps because he felt incumbents were expressly favored, saying, "This is the culmination of a years long effort to maintain the status quo. They did not hide the fact that the goal was to let the incumbents draw the maps as they pleased.”

Drafting process

In Rhode Island, both congressional and state legislative district boundaries are drawn by the Rhode Island General Assembly. These lines are subject to veto by the governor.

An 18-member advisory commission established in 2011 can recommend congressional and state legislative redistricting plans to the state legislature. The legislature may "adopt, modify, or ignore the commission's proposals." The composition of the commission is as follows:

1. The majority leader of the Rhode Island State Senate chooses four commissioners who are state legislators and three who are not, for a total of seven commissioners.
2. The majority leader of the Rhode Island House of Representatives chooses four commissioners who are state legislators and three who are not, for a total of seven commissioners.
3. The minority leader of the Rhode Island State Senate chooses two commissioners who are state legislators.
4. The minority leader of the Rhode Island House of Representatives chooses two commissioners who are state legislators.

The Rhode Island Constitution requires that state legislative districts be compact.

State statutes require that congressional and state legislative districts meet the following criteria:

1. Districts should be contiguous.
2. Districts should "reflect natural, historical, geographical, and municipal and other political lines, 'as well as the right of all Rhode Islanders to fair representation and equal access to the political process.'"
3. "The lines of state House, state Senate and congressional districts [should] coincide–or at least, if they do not overlap completely, they should avoid creating voting precincts with distinct ballot options where the precinct has fewer than 100 people."

Timeline

The following public hearing schedule was posted on the Rhode Island Redistricting Project website.

Rhode Island public hearing schedule, 2020 cycle
Date	Location	Time
Thursday, September 9, 2021	State House, Providence	4:00 pm
Thursday, September 16, 2021	State House, Providence	4:00 pm
Thursday, September 23, 2021	State House, Providence	4:00 pm
Thursday, September 30, 2021	Newport Campus Auditorium, Newport	6:00 pm
Monday, October 4, 2021	Woonsocket High School Auditorium, Woonsocket	6:00 pm
Thursday, October 7, 2021	URI Kingston Campus, Kingston	6:00 pm
Monday, October 18, 2021	Providence Career & Technical Center Auditorium, Providence	6:00 pm
Thursday, October 21, 2021	CCRI Warwick Campus, Warwick	6:00 pm
Monday, October 25, 2021	Mount Hope High School, Bristol	6:00 pm

Committees and/or commissions involved in the process

Rhode Island Special Commission on Reappotionment Committee membership, 2020 cycle
Name	Member type	Partisan affiliation
Rep. Katherine Kazarian	Legislator
Rep. Arthur Corvese	Legislator
Rep. Grace Diaz	Legislator
Rep. Robert Phillips	Legislator
Rep. Brian Newberry	Legislator
Rep. David Place	Legislator
Sen. Stephen R. Archambault	Legislator
Sen. Walter S. Felag Jr.	Legislator
Sen. Ana Quezada	Legislator
Sen.V. Susan Sosnowski	Legislator
Sen. Jessica de la Cruz	Legislator
Sen. Gordon Rogers	Legislator
Alvin Reyes	Citizen	N/A
Harold M. Metts	Citizen	N/A
Maria Bucci	Citizen	N/A
Stephen Ucci	Citizen	N/A
Antonio "Tony" Lopes	Citizen	N/A
Kaprece Ransaw	Citizen	N/A

Pre-drafting developments

The Rhode Island General Assembly's Special Commission on Reapportionment held its first meeting on September 9, 2021. The meeting focused on the commission's organization, including the election of co-chairs from each chamber of the legislature.

On January 5, 2022, the Reapportionment Commission voted 15-1 to approve new guidelines concerning the residency status of prison inmates. Under the new rules, inmates incarcerated for less than two years will be counted as residents of their former residences in future General Assembly and Congressional map drafts. Previously, inmates were considered residents of the districts where they were incarcerated.

Drafts and Proposals

Congressional proposals

The House and Senate passed congressional maps on February 15, 2022. The House voted 58 to 8 to approve the proposal and the Senate passed the map 29 to 9.

Legislative proposals

The Rhode Island Special Commission on Reapportionment released map proposals for General Assembly districts on December 3, 2021. The commission released a third Senate proposal on December 9, and a third House proposal on December 13. On January 12, 2022, the commission voted to approve state House and Senate maps in a 13-4 vote and approved a congressional map in a 15-2 vote. The House and Senate passed legislative maps on February 15. The House voted 58 to 8 to approve the proposals and the Senate passed them 29 to 9.

Map images

Click below to see images of proposed House districts.

• House Plan A
• House Plan B
• House Plan C
• House Plan D

Click below to see images of proposed Senate districts.

• Senate Plan A
• Senate Plan B
• Senate Plan C
• Senate Plan D

Apportionment and release of census data

Apportionment is the process by which representation in a legislative body is distributed among its constituents. The number of seats in the United States House of Representatives is fixed at 435. The United States Constitution dictates that districts be redrawn every 10 years to ensure equal populations between districts. Every ten years, upon completion of the United States census, reapportionment occurs.

Apportionment following the 2020 census

The U.S. Census Bureau delivered apportionment counts on April 26, 2021. Rhode Island was apportioned two seats in the U.S. House of Representatives. This represented neither a gain nor a loss of seats as compared to apportionment after the 2010 census.

See the table below for additional details.

2020 and 2010 census information for Rhode Island
State	2010 census		2020 census		2010-2020
	Population	U.S. House seats	Population	U.S. House seats	Raw change in population	Percentage change in population	Change in U.S. House seats
Rhode Island	1,055,247	2	1,098,163	2	42,916	4.07%	0

Redistricting data from the Census Bureau

On February 12, 2021, the Census Bureau announced that it would deliver redistricting data to the states by September 30, 2021. On March 15, 2021, the Census Bureau released a statement indicating it would make redistricting data available to the states in a legacy format in mid-to-late August 2021. A legacy format presents the data in raw form, without data tables and other access tools. On May 25, 2021, Ohio Attorney General Dave Yost (R) announced that the state had reached a settlement agreement with the Census Bureau in its lawsuit over the Census Bureau's timetable for delivering redistricting data. Under the terms of the settlement, the Census Bureau agreed to deliver redistricting data, in a legacy format, by August 16, 2021. The Census Bureau released the 2020 redistricting data in a legacy format on August 12, 2021, and in an easier-to-use format at data.census.gov on September 16, 2021.

Court challenges

If you are aware of any relevant lawsuits that are not listed here, please email us at editor@ballotpedia.org.

This section will include information regarding legal challenges to enacted maps.

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.

“	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.	”
—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."

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."

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."

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.
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.
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.
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.

Methods

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

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.

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.

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.

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 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.

Show more

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." 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. The U.S. Supreme Court scheduled oral argument on this case for October 11, 2023.

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. 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.

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.

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.

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.

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.

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.

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.

Trifectas and redistricting

In 34 of the states that conducted legislative elections in 2020, the legislatures themselves played a significant part in the subsequent redistricting process. The winner of eight of 2020's gubernatorial elections had veto authority over state legislative or congressional district plans approved by legislatures. The party that won trifecta control of a state in which redistricting authority rests with the legislature directed the process that produces the maps that will be used for the remainder of the decade. Trifecta shifts in the 2010 election cycle illustrate this point. In 2010, 12 states in which legislatures had authority over redistricting saw shifts in trifecta status. Prior to the 2010 elections, seven of these states were Democratic trifectas; the rest were divided governments. After the 2010 elections, seven of these states became Republican trifectas; the remainder either remained or became divided governments. The table below details these shifts and charts trifecta status heading into the 2020 election cycle.

The 12 legislature-redistricting states that saw trifecta shifts in 2010 – subsequent trifecta status

State	Primary redistricting authority	Pre-2010 trifecta status	Post-2010 trifecta status	Post-2018 trifecta status
Alabama	Legislature	Divided	Republican	Republican
Colorado	Congressional maps: legislature State legislative maps: politician commission	Democratic	Divided	Democratic
Indiana	Legislature	Divided	Republican	Republican
Iowa	Legislature	Democratic	Divided	Republican
Maine	Legislature	Democratic	Republican	Democratic
Michigan	Legislature	Divided	Republican	Divided
New Hampshire	Legislature	Democratic	Divided	Divided
North Carolina	Legislature	Democratic	Divided	Divided
Ohio	Congressional maps: legislature State legislative maps: politician commission	Divided	Republican	Republican
Oregon	Legislature	Democratic	Divided	Democratic
Pennsylvania	Congressional maps: legislature State legislative maps: politician commission	Divided	Republican	Divided
Wisconsin	Legislature	Democratic	Republican	Divided

2010 redistricting cycle

Redistricting in Rhode Island after the 2010 census

Following the 2010 United States Census, Rhode Island neither gained nor lost congressional seats. On December 19, 2011, the advisory redistricting commission issued its recommendations for new congressional and state legislative district boundaries. On February 2, 2012, the legislature approved congressional and state legislative redistricting plans, which were signed into law by the governor on February 8, 2012.

See also

• Redistricting in Rhode Island after the 2010 census
• Redistricting in Rhode Island
• State-by-state redistricting procedures
• Majority-minority districts

External links

• Search Google News for this topic
• All About Redistricting
• Dave's Redistricting
• FiveThirtyEight, "What Redistricting Looks Like In Every State"
• National Conference of State Legislatures, "Redistricting Process"
• FairVote, "Redistricting"