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Redistricting in Virginia after the 2020 census

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Redistricting
State legislative and congressional redistricting after the 2020 census
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.

The Virginia Supreme Court unanimously approved congressional maps for the state on December 28, 2021.[1] The Virginia Redistricting Commission released two statewide congressional map proposals on October 14, 2021, and another on October 15, 2021.[2] After the commission missed its deadline for approving map proposals and the Virginia Supreme Court assumed authority over the process, the two special masters selected by the court released proposals for congressional districts on December 8, 2021.[3]

The Virginia Supreme Court unanimously approved district maps for the Virginia House of Delegates and Virginia State Senate on December 28, 2021.[4] Democratic and Republican consultants submitted statewide map proposals for consideration to the Virginia Redistricting Commission on September 18, 2021.[5] The commission had reviewed earlier maps on August 31, 2021, that were focused solely on suburbs in northern Virginia that were drawn from scratch and did not consider legislative incumbents’ home addresses in keeping with earlier commission decisions.[6][7] After the commission missed its deadline for approving map proposals and the Virginia Supreme Court assumed authority over the process, the two special masters selected by the court released proposals for House and Senate districts on December 8, 2021.[8]These maps took effect for Virginia's 2023 legislative elections.

Click here for more information.

Virginia's 11 United States representatives and 140 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.This article chronicles the 2020 redistricting cycle in Virginia.

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 Virginia 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.

  • Decemeber 28, 2021: The Virginia Supreme Court unanimously approved new congressional and state legislative maps.
  • Decemeber 8, 2021: The two special masters appointed by the court released map drafts for state legislative and congressional districts.
  • November 19, 2021: The court unanimously approved two of the nominees: Sean Trende, who was the Republican special master nominee, and Bernard Grofman, who was the Democratic nominee.
  • November 15, 2021: The court granted a three-day extension for legislators to make new special master nominations.
  • November 12, 2021: The court rejected all three Republican nominees and one Democratic nominee for special master and requested that legislators submit new nominations by November 15.
  • November 8, 2021: The commission did not produce congressional maps by the final deadline, and authority to redraw congressional districts passed to the Virginia Supreme Court.
  • October 24, 2021: The Virginia Redistricting Commission did not produce final state legislative by its October 24, 2021 deadline, and the authority to draw new district maps passed to the Virginia Supreme Court.
  • October 15, 2021: The commission released two statewide congressional map proposals on October 14, 2021, and another on October 15.
  • October 13, 2021: U.S. District Judge David Novak ruled court challenge to the November House of Delegates elections could move forward and appointed two other judges, Fourth Circuit Judge Stephanie Thacker and U.S. District Judge Raymond Jackson, to hear the case.
  • October 10, 2021:The Virginia Redistricting Commission did not meet the October 10 deadline to submit state legislative maps to the General Assembly. If the commission does not reconvene to draft maps, the authority to create new state legislative districts passes to the Virginia Supreme Court.
  • September 27, 2021: Democratic and Republican map drawers submitted a collaborative statewide map proposal for consideration to the commission.
  • September 23, 2021: The Virginia Supreme Court rejected a lawsuit challenging how inmates are counted.
  • September 18, 2021: Democratic and Republican map drawers each submitted statewide map proposals for consideration to the commission.
  • September 16, 2021: The commission voted to restrict its map drawers from looking at political data or incumbents' residences while drafting maps of General Assembly and congressional 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 13, 2021: The commission dropped the regional approach to map drafting in favor of drafting statewide maps.
  • September 8, 2021: State Sen. Bill Stanley (R) replaced Steve Newman (R) on the commission.
  • September 4, 2021: State Sen. Steve Newman (R) announced his resignation from the commission.
  • August 24, 2021: The commission announced that a member had tested positive for COVID-19 and that it would not hold its next scheduled meeting on August 30.
  • August 23, 2021: The commission voted 12-4 to redraw district maps from scratch rather than using the current maps as a guide.
  • August 17, 2021: The commission voted to allow political data and incumbents’ home addresses to be considered throughout the map-drawing process.
  • August 16, 2021: The commission voted to officially start the state’s redistricting process on August 26, 2021.
  • August 13, 2021: Six county supervisors and State Sen. Travis Hackworth (R) filed a lawsuit against the commission asking the Supreme Court of Virginia to intervene in the commission's plans to count prisoners at their last known address instead of where they are currently incarcerated.
  • August 12, 2021: The U.S. Census Bureau delivered redistricting data to states in a legacy format.
  • July 6, 2021: Paul Goldman (D) filed a complaint with the United States District Court for the Eastern District of Virginia arguing that holding the November 2021 House elections with districts drawn in 2010 violates Virginia’s Constitution and the Equal Protection Clause of the U.S. Constitution.
  • June 7, 2021: The commission decided against a proposal to hire nonpartisan counsel, instead opting to hire two sets of partisan attorneys.
  • 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

The Virginia Supreme Court unanimously approved congressional maps for the state on December 28, 2021.[9] The Virginia Redistricting Commission released two statewide congressional map proposals on October 14, 2021, and another on October 15, 2021.[10] After the commission missed its deadline for approving map proposals and the Virginia Supreme Court assumed authority over the process, the two special masters selected by the court released proposals for congressional districts on December 8, 2021.[11]

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

Virginia Congressional Districts
until January 2, 2023

Click a district to compare boundaries.

Virginia Congressional Districts
starting January 3, 2023

Click a district to compare boundaries.


Reactions

Liz White, the director of redistricting reform organization One Virginia 2021, said, "They're definitely the best maps we’ve seen in Virginia in a long time. It’s the first set of maps that haven’t been drawn at all by any member of the legislature, by any member of any political party."[12]

Ben Cline (R) said "I look forward to the opportunity of introducing myself to the new voters added to VA-6 including the Counties of Frederick, Clarke, and Alleghany, and the Cities of Winchester, Covington, and Salem. However, I am disappointed I will no longer have the privilege of representing so many friends and neighbors in Amherst and Bedford Counties and the City of Lynchburg."[13]

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.[14] This data was compiled by Daily Kos Elections.[15]

2020 presidential results by Congressional district, Virginia
District 2022 district Political predecessor district
Joe Biden Democratic Party Donald Trump Republican Party Joe Biden Democratic Party Donald Trump Republican Party
Virginia's 1st 46.2% 52.3% 47.0% 51.4%
Virginia's 2nd 50.1% 48.2% 51.4% 46.7%
Virginia's 3rd 68.3% 30.0% 67.2% 31.2%
Virginia's 4th 67.2% 31.5% 61.8% 36.8%
Virginia's 5th 45.2% 53.4% 45.1% 53.6%
Virginia's 6th 38.4% 60.0% 38.6% 59.8%
Virginia's 7th 52.6% 45.8% 49.8% 48.7%
Virginia's 8th 77.4% 21.3% 77.6% 21.1%
Virginia's 9th 28.5% 70.3% 28.4% 70.4%
Virginia's 10th 58.3% 40.2% 58.9% 39.6%
Virginia's 11th 70.0% 28.7% 70.3% 28.3%

Enacted state legislative district maps

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

The Virginia Supreme Court unanimously approved district maps for the Virginia House of Delegates and Virginia State Senate on December 28, 2021.[16] Democratic and Republican consultants submitted statewide map proposals for consideration to the Virginia Redistricting Commission on September 18, 2021.[17] The commission had reviewed earlier maps on August 31, 2021, that were focused solely on suburbs in northern Virginia that were drawn from scratch and did not consider legislative incumbents’ home addresses in keeping with earlier commission decisions.[18][19] After the commission missed its deadline for approving map proposals and the Virginia Supreme Court assumed authority over the process, the two special masters selected by the court released proposals for House and Senate districts on December 8, 2021.[20]These maps took effect for Virginia's 2023 legislative elections.

State Senate map

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

Virginia State Senate Districts
until January 9, 2024

Click a district to compare boundaries.

Virginia State Senate Districts
starting January 10, 2024

Click a district to compare boundaries.

State House map

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

Virginia State House Districts
until January 9, 2024

Click a district to compare boundaries.

Virginia State House Districts
starting January 10, 2024

Click a district to compare boundaries.


Reactions

Del. Sally Hudson (D) said “The special masters drew sensible districts that respect the Charlottesville-Albemarle region as the community we are. After a decade of fractured lines that left us with six different representatives in Richmond, our City and County will now have two Delegates, one Senator, and a coherent, empowered voice in state politics.”[21]

State Sen. Scott Surovell (D) said "The law says that 'A map of districts shall not, when considered on a statewide basis, unduly favor or disfavor any political party' - D's have won every statewide election since 2009 except the last which didn't by 40-80K votes of 3.2M cast. This does not merit for toss up maps."[22] In a public hearing prior to the court's approval of the map, Gary Hodnett, the mayor of Hurt, Virginia, said the proposed maps would separate voters in the Hurt area from their communities of interest. “We are obviously more aligned with our surrounding communities like Motley, Grit and Renan. We work closely with our neighboring towns of Gretna and Chatham,” said Hodnett.[23]


Drafting process

On November 3, 2020, Virginia voters approved a constitutional amendment establishing a commission-driven congressional and state legislative redistricting process. The 16-member commission comprises eight legislators and eight non-legislator members. Leaders of the legislature's two largest political parties select legislators to serve on the commission. The commission's eight citizen members are recommended by legislative leaders and selected by a committee of five retired circuit court judges. The commissioners themselves select one of the eight citizens to serve as chairperson.[24]

District maps are subject to the following consensus requirements:[24]

  • Congressional maps: Approval by 12 commissioners, including six legislators and six non-legislators.
  • Virginia State Senate: Approval by 12 commissioners, including six legislators (with three state senators) and six non-legislators.
  • Virginia House of Delegates: Approval by 12 commissioners, including six legislators (with three state delegates) and six non-legislators.

The commission submits its maps to the General Assembly, which can vote to approve the maps or reject them. The General Assembly cannot amend the maps. If the General Assembly rejects a map, the commission must draft a second map. If the General Assembly rejects that map, the Virginia Supreme Court is tasked with enacting a new map.[24][25]

Timeline

The following timeline was adapted from a timeline constructed by the Virginia Civic Engagement Table and information provided by the Virginia Redistricting Commission.[26][27]

Projected redistricting timeline for Virginia, 2020 cycle
Date Event
December 1, 2020 Citizen Member applications are made public
December 28, 2020 Citizen Member applications must be submitted (with 3 references)
January 1, 2021 General Assembly Leadership each submit a list of Citizen Member Nominees
January 15, 2021 Judge Selection Committee selects Citizen Members
February 1, 2021 First Commission Meeting must be held and a Citizen Chair must be elected
August, 2021 The Commission receives Census data
October 10, 2021 House and Senate maps due
October 25, 2021 Congressional maps due
November 9, 2021 Deadline for General Assembly to approve maps
Novemeber 18, 2021 Deadline for submission of special masters nominations
December 19, 2021 Deadline for Virginia Supreme Court to produce maps


Committees and/or commissions involved in the process

Listed below are the members of the Virginia Redistricting Commission in the 2020 cycle.[28]


Virginia Redistricting Commission membership, 2020 cycle
Name Member type Partisan affiliation
Del. Delores McQuinn Legislator Electiondot.png Democratic
Del. Marcus Simon Legislator Electiondot.png Democratic
Del. Les Adams Legislator Ends.png Republican
Del. Margaret Ransone Legislator Ends.png Republican
Sen. George Barker Legislator Electiondot.png Democratic
Sen. Mamie Locke Legislator Electiondot.png Democratic
Sen. Ryan McDougle Legislator Ends.png Republican
Sen. Bill Stanley Legislator Ends.png Republican
Greta J. Harris Citizen N/A
Brandon Christopher Hutchins Citizen N/A
Mackenzie Babichenko Citizen N/A
Jose A. Feliciano, Jr. Citizen N/A
James Abrenio Citizen N/A
Sean S. Kumar Citizen N/A
Richard O. Harrell III Citizen N/A
Virginia Trost-Thornton Citizen N/A


On July 7, 2021, Marvin Gilliam Jr., one of the eight citizen members on the commission, stepped down, citing health reasons. On July 19, 2021, the commission voted 13-1 to approve Virginia Trost-Thornton, a lawyer from Forest, Virginia, to take Gilliam's place on the committee.[29]

State Sen. Steve Newman (R) announced his resignation from the commission on September 4, 2021. “I have enjoyed working with my colleagues on the Virginia Redistricting Commission for the past nine months,” he said, but did not provide a reason for his resignation. Senate Minority Leader Tommy Norment (R) chose Sen. Bill Stanley (R) as Newman’s replacement.[30][31]


Pre-drafting developments

On September 16, 2021, the Virginia Redistricting Commission voted to restrict its map drawers from looking at political data or incumbents' residences while drafting maps of General Assembly and congressional districts. The commission's instructions said the map drawers "may not consider political data, including election results or incumbent addresses while drawing your maps," and that they "must clearly disclose on your maps every district where, prior to receiving this direction, you considered any political data in the map-drawing process."[32] The commission deadlocked 8-8 along partisan lines on the extent to which race should factor into map drawing. The commission's Democratic attorneys suggested map drawers should look for every possible chance to draw districts in which a coalition of racial minorities could elect a candidate without any one group making up a majority of a district’s voters, while Republican attorneys said seeking every chance to do this would violate constitutional provisions against making race a deciding factor.[33]


On September 13, 2021, commission co-chairs Greta Harris and Mackenzie Babichenko announced the commission would drop the regional approach to map drafting it previously used and focus on drafting statewide maps. “We were concerned around the timing that is statutorily laid out for us, that we were not going to be able to get through the large swathe of land that makes up the Commonwealth of Virginia in the way we were doing it by regions," said Harris. Following the new plan, commission consultants will create statewide district maps for the House of Delegates and state Senate and present these to the commission on September 20.[34]

On August 23, 2021, the commission voted 12-4 to redraw district maps from scratch rather than using the current maps as a guide. The vote came after voters voiced concern that the earlier maps were too partisan. The redrawing process will begin on August 26 after analysts produce new population estimates. Following the commission's earlier plans to hire analysts aligning with each major party, Republicans chose John Morgan, who assisted in the drafting of the House of Delegates maps for Republicans in 2011, and Democrats chose Ken Strasma, the CEO of analytics firm HaystaqDNA.[35]

On August 17, 2021, the commission voted to allow political data and incumbents’ home addresses to be considered throughout the map-drawing process. In another vote on a plan to hire geographic data specialists from the University of Richmond, the commission was deadlocked and the issue remains unresolved.[36]

On June 7, 2021, the commission decided against a proposal to hire nonpartisan counsel, instead opting to hire two sets of partisan attorneys. In a 10-4 vote, the commission decided to issue requests for proposals designed to choose one Democratic firm and one Republican firm to advise the commission. A majority of elected Democrats and all Republicans on the 16-person commission voted to hire partisan attorneys. Greta Harris, a Democratic co-chair of the commission, and Del. Delores McQuinn (D) were absent. The attorneys will not be involved in creating district maps, but will help the commission determine whether its decisions comply with redistricting laws.[37]

Commission votes to start process on Aug. 26

On August 16, 2021, the Virginia Redistricting Commission voted to officially start the state’s redistricting process on August 26, 2021. The commission is expected to receive data that an outside consultant is reformatting by that date. The Census Bureau released block-level data from the 2020 census on August 12, 2021. State law requires that the commission submit proposed state legislative maps to the General Assembly within 45 days of receiving census data and proposed congressional district boundaries within 60 days.[38]

Commission misses deadlines to submit proposals

The commission did not meet the October 10 deadline to submit state legislative maps to the General Assembly. Under state law, the commission is given 14 days after “its initial failure to submit a plan to the General Assembly.” If the commission does not reconvene to draft maps, the authority to create new districts passes to the Virginia Supreme Court, which as of October 2021 was made up of a majority of Republican-appointed judges.[39]

The commission did not produce final state legislative by its October 24, 2021 deadline, and the authority to draw new district maps passed to the Virginia Supreme Court. The commission had until November 8, 2021 to produce a congressional district map.[40] Since the commission did not produce congressional maps by the final deadline, authority to redraw congressional districts passed to the Virginia Supreme Court. Each party in the legislature was required to nominate three special masters to assist the court, which they did on November 1, 2021. State Democrats nominated three professors, Bernard N. Grofman, Nathaniel Persily, and Bruce E. Cain, who had all participated in previous redistricting efforts. Republican nominees Thomas Bryan, Adam Kincaid, and Adam Foltz also had previous experience in redistricting.[41]

The Virginia Supreme Court rejected all three Republican nominees and one Democratic nominee for special master on November 12, 2021, and requested that legislators submit new nominations by November 15.[42] On November 15, the Virginia Supreme Court granted a three-day extension for legislators to make new special master nominations.[43] On November 19, 2021, the Virginia Supreme Court unanimously approved two of the nominees: Sean Trende, who was the Republican special master nominee, and Bernard Grofman, who was the Democratic nominee.[44]

Drafts and proposals

Legislative maps

Democratic and Republican map drawers submitted statewide map proposals for consideration to the Virginia Redistricting Commission on September 18, 2021.[45] The commission had reviewed earlier maps on August 31 that were focused solely on suburbs in northern Virginia that were drawn from scratch and did not consider legislative incumbents’ home addresses in keeping with earlier commission decisions.[46][47]

After the commission missed its deadline for approving map proposals and the Virginia Supreme Court assumed authority over the process, the two special masters selected by the court released proposals for House and Senate districts on December 8.[48]

Map images

Click the links below to view submitted proposals.

Congressional maps

The Virginia Redistricting Commission released two statewide congressional map proposals on October 14, 2021, and another on October 15.[49] After the commission missed its deadline for approving map proposals and the Virginia Supreme Court assumed authority over the process, the two special masters selected by the court released proposals for congressional districts on December 8.[50]

Map images

Click the links below to view submitted proposals.

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.[51]

Apportionment following the 2020 census

The U.S. Census Bureau delivered apportionment counts on April 26, 2021. Virginia was apportioned 11 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.[52]

See the table below for additional details.

2020 and 2010 census information for Virginia
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
Virginia 8,037,736 11 8,654,542 11 616,806 7.67% 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.[53][54][55][56] 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.[57][58]

Court challenges

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

Thomas v. Beals

On June 8, 2022, a Virginia voter filed a lawsuit in the United States District Court for the Eastern District of Virginia against Susan Brink, Commissioner of the Virginia Department of Elections, and Robert Brink, Chairman of the Virginia Department of Elections, arguing that the state's 2021 legislative elections were conducted using invalid and unconstitutional districts that were adopted after the 2010 census.[59] The United States Census Bureau released block-level data from the 2020 census to the states on August 12, 2021. The lawsuit asked the court to order Virginia to hold elections for the House of Delegates using boundaries enacted after the 2020 census at the next possible general election in November 2022, rather than at the next scheduled date in November 2023.[59] On August 1, 2022, the federal district court dismissed the lawsuit, saying, "The global pandemic delayed the reapportionment process, just as it disrupted nearly every aspect of American life. As a result of this disruption, and through no fault of Defendants, Virginia held an election using districts previously redrawn by this Court. And, it will hold the next election using different maps drawn by the Supreme Court of Virginia in accord with the Constitution of Virginia...At bottom, Plaintiffs claim an injury that Defendants did not cause and that the Court cannot redress. Accordingly, Plaintiffs lack standing to bring these claims, and the Court lacks subject matter jurisdiction to adjudicate them."[60]

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.[61][62]

“ 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.[63] ”
—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."[64][65][66]

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."[66]

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."[66]

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.[66][67]
  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.[66][67]
  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.[66][67]
  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.[66][67]

Methods

In general, a state's redistricting authority can be classified as one of the following:[68]

  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.[69][70]

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.[71]

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.[72][73]

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."[74] 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.[75] The U.S. Supreme Court scheduled oral argument on this case for October 11, 2023.[76]

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.[77] 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.[78]

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.[79]

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.[80]

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.[81][82][83]

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.[84][85][86][87]

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.[88][89][90]

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.[91][92][93][94]

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 Virginia after the 2010 census

Virginia's congressional and state legislative district maps, drawn after the 2010 census, were subject to legal challenges. For more information see this article.

See also

External links

Footnotes

  1. ↑ 13News Now, "Virginia has new voting maps after redistricting process finishes," December 30, 2021
  2. ↑ Virginia Redistricting, "Congressional," accessed October 19, 2021
  3. ↑ Associated Press, "Proposed congressional maps give Dems an edge in Virginia," December 9, 2021
  4. ↑ 13News Now, "Virginia has new voting maps after redistricting process finishes," December 30, 2021
  5. ↑ ABC 7, "Virginia bipartisan redistricting panel starts off with partisan maps," September 20, 2021
  6. ↑ El Paso Inc., "First redistricting map drafts leave some lawmakers unhappy," September 2, 2021
  7. ↑ Virginia Mercury, "Virginia’s Redistricting Commission has its first draft maps. They look… normal?" September 2, 2021
  8. ↑ Associated Press, "Proposed congressional maps give Dems an edge in Virginia," December 9, 2021
  9. ↑ 13News Now, "Virginia has new voting maps after redistricting process finishes," December 30, 2021
  10. ↑ Virginia Redistricting, "Congressional," accessed October 19, 2021
  11. ↑ Associated Press, "Proposed congressional maps give Dems an edge in Virginia," December 9, 2021
  12. ↑ 13News Now, "Virginia has new voting maps after redistricting process finishes," December 30, 2021
  13. ↑ WSET, "Virginia Supreme Court approves new congressional and General Assembly districts," December 29, 2021
  14. ↑ Political predecessor districts are determined primarily based on incumbents and where each chose to seek re-election.
  15. ↑ Daily Kos Elections, "Daily Kos Elections 2020 presidential results by congressional district (old CDs vs. new CDs)," accessed May 12, 2022
  16. ↑ 13News Now, "Virginia has new voting maps after redistricting process finishes," December 30, 2021
  17. ↑ ABC 7, "Virginia bipartisan redistricting panel starts off with partisan maps," September 20, 2021
  18. ↑ El Paso Inc., "First redistricting map drafts leave some lawmakers unhappy," September 2, 2021
  19. ↑ Virginia Mercury, "Virginia’s Redistricting Commission has its first draft maps. They look… normal?" September 2, 2021
  20. ↑ Associated Press, "Proposed congressional maps give Dems an edge in Virginia," December 9, 2021
  21. ↑ The Roanoake Times, "Gibson: Political party parity at work in Virginia's proposed congressional redistricting maps," January 2, 2022
  22. ↑ Courthouse News, "Virginia high court gives final approval to new election maps," December 29, 2021
  23. ↑ Chatham Star Tribune, "Final redistricting map separates Hurt voters from rest of County," December 29, 2021
  24. ↑ 24.0 24.1 24.2 Virginia's Legislative Information System, "HJ 615 Constitutional amendment; Virginia Redistricting Commission (first reference)," accessed November 18, 2020
  25. ↑ All About Redistricting, "Virginia," accessed May 8, 2015
  26. ↑ Virginia Civic Engagement Table, "Redistricting," accessed December 15, 2020
  27. ↑ Virginia Redistricting Commission, "Map Submission Timeline," accessed August 31, 2021
  28. ↑ Virginia Redistricting Commission, "Eight Citizen Members Selected for Virginia Redistricting Commission," January 6, 2021
  29. ↑ Virginia Public Radio, "With Monday Vote, SW Virginia Stays Unrepresented on Redistricting Commission," July 19, 2021
  30. ↑ WFXR, "Republican state senator to step down from Virginia Redistricting Commission," September 4, 2021
  31. ↑ The News and Advance, "Stanley replacing Newman on Virginia's redistricting commission," September 8, 2021
  32. ↑ NBC 12, "Va. Redistricting Commission approves neutrality rule, deadlocks on use of race," September 16, 2021
  33. ↑ Virginia Mercury, "Va. Redistricting Commission approves neutrality rule, deadlocks on use of race," September 16, 2021
  34. ↑ Virginia Mercury, "Redistricting Commission drops region-by-region approach, expects statewide maps Sept. 20," September 13, 2021
  35. ↑ The Hill, "Virginia commission will redraw districts from scratch," August 24, 2021
  36. ↑ Fauquier Inquirer, "Va. Redistricting Commission votes to allow use of political data, reject university map-drawers," August 18, 2021
  37. ↑ Virginia Mercury, "In divided vote, Va. Redistricting Commission chooses to hire partisan lawyers," June 7, 2021
  38. ↑ 13NewsNow, "Virginia Redistricting Commission delays deadline, debates map drawers and plans ahead of important decisions," August 16, 2021
  39. ↑ NBC Washington, "Virginia Redistricting Commission May Give Up on Updating State Maps," October 12, 2021
  40. ↑ Washington Post, "Virginia’s redistricting commission’s failure to transcend partisanship has lessons for other states, critics say," October 25, 2021
  41. ↑ Richmond Times-Dispatch, "Six candidates recommended as 'special masters' to help justices with Virginia redistricting," November 5, 2021
  42. ↑ Washington Examiner, "Virginia Supreme Court rejects Republican nominee for drawing new redistricting maps," November 12, 2021
  43. ↑ The Gazette, "Virginia Supreme Court extends deadline for redistricting map drawer nominations," November 16, 2021
  44. ↑ WRIC, "Virginia Supreme Court appoints two map drawers to help with state’s political redistricting," November 19, 2021
  45. ↑ ABC 7, "Virginia bipartisan redistricting panel starts off with partisan maps," September 20, 2021
  46. ↑ El Paso Inc., "First redistricting map drafts leave some lawmakers unhappy," September 2, 2021
  47. ↑ Virginia Mercury, "Virginia’s Redistricting Commission has its first draft maps. They look… normal?" September 2, 2021
  48. ↑ Associated Press, "Proposed congressional maps give Dems an edge in Virginia," December 9, 2021
  49. ↑ Virginia Redistricting, "Congressional," accessed October 19, 2021
  50. ↑ Associated Press, "Proposed congressional maps give Dems an edge in Virginia," December 9, 2021
  51. ↑ United States Census Bureau, "Apportionment," accessed July 11, 2018
  52. ↑ United States Census Bureau, "2020 Census Apportionment Results Delivered to the President," April 26, 2021
  53. ↑ United States Census Bureau, "2020 Census Operational Plan: Executive Summary," December 2015
  54. ↑ United States Census Bureau, "Census Bureau Statement on Redistricting Data Timeline," February 12, 2021
  55. ↑ Office of the Attorney General of Ohio, "AG Yost Secures Victory for Ohioans in Settlement with Census Bureau Data Lawsuit," May 25, 2021
  56. ↑ U.S. Census Bureau, "U.S. Census Bureau Statement on Release of Legacy Format Summary Redistricting Data File," March 15, 2021
  57. ↑ U.S. Census Bureau, "Decennial Census P.L. 94-171 Redistricting Data," accessed August 12, 2021
  58. ↑ United States Census Bureau, "Census Bureau Delivers 2020 Census Redistricting Data in Easier-to-Use Format," September 16, 2021
  59. ↑ 59.0 59.1 United States District Court for the Eastern District of Virginia, Thomas v. Beals, et al, June 8, 2022
  60. ↑ United States District Court for the Eastern District of Virginia, Thomas, et al v. Beals, et al, August 1, 2022
  61. ↑ The Heritage Guide to the Constitution, "Election Regulations," accessed April 13, 2015
  62. ↑ Brookings, "Redistricting and the United States Constitution," March 22, 2011
  63. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
  64. ↑ Brennan Center for Justice, "A Citizen's Guide to Redistricting," accessed March 25, 2015
  65. ↑ The Constitution of the United States of America, "Article 1, Section 2," accessed March 25, 2015
  66. ↑ 66.0 66.1 66.2 66.3 66.4 66.5 66.6 All About Redistricting, "Where are the lines drawn?" accessed April 9, 2015
  67. ↑ 67.0 67.1 67.2 67.3 FairVote, "Redistricting Glossary," accessed April 9, 2015
  68. ↑ All About Redistricting, "Who draws the lines?" accessed June 19, 2017
  69. ↑ All About Redistricting, "Why does it matter?" accessed April 8, 2015
  70. ↑ Encyclopædia Britannica, "Gerrymandering," November 4, 2014
  71. ↑ Congressional Research Service, "Congressional Redistricting and the Voting Rights Act: A Legal Overview," April 13, 2015
  72. ↑ The Wall Street Journal, "Supreme Court to Consider Limits on Partisan Drawing of Election Maps," June 19, 2017
  73. ↑ The Washington Post, "Supreme Court to hear potentially landmark case on partisan gerrymandering," June 19, 2017
  74. ↑ 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
  75. ↑ Supreme Court of the United States, "Alexander, et al. v. The South Carolina State Conference of the NAACP, et al.," February 17, 2023
  76. ↑ SCOTUSblog, "Alexander v. South Carolina State Conference of the NAACP," accessed July 21, 2023
  77. ↑ SCOTUSblog, "Justices will hear case that tests power of state legislatures to set rules for federal elections," June 30, 2022
  78. ↑ 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
  79. ↑ SCOTUSblog.org, "Supreme Court upholds Section 2 of Voting Rights Act," June 8, 2023
  80. ↑ Supreme Court of the United States, "Gill v. Whitford: Decision," June 18, 2018
  81. ↑ Election Law Blog, "Breaking: SCOTUS to Hear NC Racial Gerrymandering Case," accessed June 27, 2016
  82. ↑ Ballot Access News, "U.S. Supreme Court Accepts Another Racial Gerrymandering Case," accessed June 28, 2016
  83. ↑ Supreme Court of the United States, "Cooper v. Harris: Decision," May 22, 2017
  84. ↑ The Washington Post, "Supreme Court to hear challenge to Texas redistricting plan," May 26, 2015
  85. ↑ The New York Times, "Supreme Court Agrees to Settle Meaning of ‘One Person One Vote,'" May 26, 2015
  86. ↑ SCOTUSblog, "Evenwel v. Abbott," accessed May 27, 2015
  87. ↑ Associated Press, "Supreme Court to hear Texas Senate districts case," May 26, 2015
  88. ↑ SCOTUSblog, "The new look at 'one person, one vote,' made simple," July 27, 2015
  89. ↑ Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission: Brief for Appellants," accessed December 14, 2015
  90. ↑ Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission," April 20, 2016
  91. ↑ The New York Times, "Court Skeptical of Arizona Plan for Less-Partisan Congressional Redistricting," March 2, 2015
  92. ↑ The Atlantic, "Will the Supreme Court Let Arizona Fight Gerrymandering?" September 15, 2014
  93. ↑ United States Supreme Court, "Arizona State Legislature v. Arizona Independent Redistricting Commission: Opinion of the Court," June 29, 2015
  94. ↑ The New York Times, "Supreme Court Upholds Creation of Arizona Redistricting Commission," June 29, 2015
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