Redistricting in Florida

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Redistricting is the process by which new congressional and state legislative district boundaries are drawn. Each of Florida's 27 United States Representatives and 160 state legislators are elected from political divisions called districts. United States Senators are not elected by districts, but by the states at large. District lines are redrawn every 10 years following completion of the United States census. The federal government stipulates that districts must have nearly equal populations and must not discriminate on the basis of race or ethnicity.[1][2][3][4]

Florida was apportioned 28 seats in the U.S. House of Representatives after the 2020 census, one more than it received after the 2010 census. Click here for more information about redistricting in Florida after the 2020 census.

HIGHLIGHTS
  • Following the 2020 United States Census, Florida was apportioned 28 congressional districts, one more than the number it had after the 2010 census.
  • Florida's House of Representatives is made up of 120 districts; Florida's State Senate is made up of 40 districts.
  • In Florida, both congressional and state legislative district lines are drawn by the state legislature.

    • On September 2, 2023, Leon County Circuit Court Judge J. Lee Marsh overturned Florida's congressional district boundaries in North Florida and enjoined the state from using the current districts in future elections. Marsh declared the current map unconstitutional and in violation of the U.S. Constitution's 14th Amendment and directed the legislature to enact new district boundaries. In his order, Marsh wrote, "This case is about whether the Legislature, in enacting its most recent congressional redistricting plan, violated the Florida Constitution by diminishing the ability of Black voters in North Florida to elect representatives of their choice. It is also about whether that provision of the Florida Constitution violates the 14th Amendment to the U.S. Constitution. In short, the answers are yes and no, respectively. For those reasons, this Court will declare the enacted map unconstitutional and enjoin the Secretary of State from using that map in future congressional elections. This Court will return the matter to the Legislature to enact a new map which complies with the Florida Constitution."[5]

    On September 4, 2023, Florida Secretary of State Cord Byrd filed notice that he and the legislature would appeal Marsh's decision to the Florida First District Court of Appeal. [6] Byrd said, "We disagree with the trial court’s decision. This is why the stipulation contemplates an appeal with pass through jurisdiction to the Florida Supreme Court which we will be pursuing.”[7]

    On March 3, 2022, the Florida Supreme Court approved new legislative maps drawn by the Florida State Legislature. These maps took effect for Florida's 2022 legislative elections. Click here for more information on maps enacted after the 2020 census.

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

    1. Background: A summary of federal requirements for redistricting at both the congressional and state legislative levels
    2. State process: An overview about the redistricting process in Florida
    3. District maps: Information about the current district maps in Florida
    4. Redistricting by cycle: A breakdown of the most significant events in Florida's redistricting after recent censuses
    5. State legislation and ballot measures: State legislation and state and local ballot measures relevant to redistricting policy
    6. Political impacts of redistricting: An analysis of the political issues associated with redistricting

    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.[8][9]

    “ 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.[10] ”
    —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."[11][12][13]

    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."[13]

    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."[13]

    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.[13][14]
    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.[13][14]
    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.[13][14]
    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.[13][14]

    Methods

    In general, a state's redistricting authority can be classified as one of the following:[15]

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

    Gerrymandering

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

    The term gerrymandering refers to the practice of drawing electoral district lines to favor one political party, individual, or constituency over another. When used in a rhetorical manner by opponents of a particular district map, the term has a negative connotation but does not necessarily address the legality of a challenged map. The term can also be used in legal documents; in this context, the term describes redistricting practices that violate federal or state laws.[1][16]

    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.[17]

    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.[18][19]

    Recent court decisions

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

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

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

    Show more

    Gill v. Whitford (2018)

    See also: Gill v. Whitford

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

    Cooper v. Harris (2017)

    See also: Cooper v. Harris

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

    Evenwel v. Abbott (2016)

    See also: Evenwel v. Abbott

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

    Harris v. Arizona Independent Redistricting Commission (2016)

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

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

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

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

    Race and ethnicity

    See also: Majority-minority districts

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

    “ No voting qualification or prerequisite to voting, or standard, practice, or procedure shall be imposed or applied by any State or political subdivision to deny or abridge the right of any citizen of the United States to vote on account of race or color.[10] ”
    —Voting Rights Act of 1965[35]

    States and other political subdivisions may create majority-minority districts in order to comply with Section 2 of the Voting Rights Act. A majority-minority district is a district in which minority groups compose a majority of the district's total population. As of 2015, Florida was home to nine congressional majority-minority districts.[2][3][4]

    Proponents of majority-minority districts maintain that these districts are a necessary hindrance to the practice of cracking, which occurs when a constituency is divided between several districts in order to prevent it from achieving a majority in any one district. In addition, supporters argue that the drawing of majority-minority districts has resulted in an increased number of minority representatives in state legislatures and Congress.[2][3][4]

    Critics, meanwhile, contend that the establishment of majority-minority districts can result in packing, which occurs when a constituency or voting group is placed within a single district, thereby minimizing its influence in other districts. Because minority groups tend to vote Democratic, critics argue that majority-minority districts ultimately present an unfair advantage to Republicans by consolidating Democratic votes into a smaller number of districts.[2][3][4]

    State process

    See also: State-by-state redistricting procedures

    In Florida, both congressional and state legislative district lines are drawn by the state legislature. Congressional lines are adopted as regular legislation and are subject to gubernatorial veto. State legislative lines are passed via joint resolution and are not subject to gubernatorial veto. State legislative district maps are automatically submitted to the Florida Supreme Court for approval. In the event that the court rejects the lines, the legislature is given a second chance to draft a plan. If the legislature cannot approve a state legislative redistricting plan, the state attorney general must ask the state supreme court to draft a plan. There are no similar procedures in place for congressional districts.[36]

    The Florida Constitution requires that all districts, whether congressional or state legislative, be contiguous. Also, "where doing so does not conflict with minority rights, [districts] must be compact and utilize existing political and geographical boundaries where feasible." Districts cannot be drawn in such a way as to "favor or disfavor a political party or incumbent."[36][37]

    How incarcerated persons are counted for redistricting

    See also: How incarcerated persons are counted for redistricting

    States differ on how they count incarcerated persons for the purposes of redistricting. In Florida, incarcerated persons are counted in the correctional facilities they are housed in.

    District maps

    Congressional districts

    See also: United States congressional delegations from Florida

    The table below lists Florida's current House representatives.


    Office Name Party Date assumed office Date term ends
    U.S. House Florida District 1 Matt Gaetz Republican January 3, 2017 January 3, 2025
    U.S. House Florida District 2 Neal Dunn Republican January 3, 2017 January 3, 2025
    U.S. House Florida District 3 Kat Cammack Republican January 3, 2021 January 3, 2025
    U.S. House Florida District 4 Aaron Bean Republican January 3, 2023 January 3, 2025
    U.S. House Florida District 5 John Rutherford Republican January 3, 2023 January 3, 2025
    U.S. House Florida District 6 Michael Waltz Republican January 3, 2019 January 3, 2025
    U.S. House Florida District 7 Cory Mills Republican January 3, 2023 January 3, 2025
    U.S. House Florida District 8 Bill Posey Republican January 3, 2013 January 3, 2025
    U.S. House Florida District 9 Darren Soto Democratic January 3, 2017 January 3, 2025
    U.S. House Florida District 10 Maxwell Alejandro Frost Democratic January 3, 2023 January 3, 2025
    U.S. House Florida District 11 Daniel Webster Republican January 3, 2017 January 3, 2025
    U.S. House Florida District 12 Gus M. Bilirakis Republican January 3, 2013 January 3, 2025
    U.S. House Florida District 13 Anna Paulina Luna Republican January 3, 2023 January 3, 2025
    U.S. House Florida District 14 Kathy Castor Democratic January 3, 2013 January 3, 2025
    U.S. House Florida District 15 Laurel Lee Republican January 3, 2023 January 3, 2025
    U.S. House Florida District 16 Vern Buchanan Republican January 3, 2013 January 3, 2025
    U.S. House Florida District 17 Greg Steube Republican January 3, 2019 January 3, 2025
    U.S. House Florida District 18 Scott Franklin Republican January 3, 2023 January 3, 2025
    U.S. House Florida District 19 Byron Donalds Republican January 3, 2021 January 3, 2025
    U.S. House Florida District 20 Sheila Cherfilus-McCormick Democratic January 18, 2022 January 3, 2025
    U.S. House Florida District 21 Brian Mast Republican January 3, 2023 January 3, 2025
    U.S. House Florida District 22 Lois Frankel Democratic January 3, 2023 January 3, 2025
    U.S. House Florida District 23 Jared Evan Moskowitz Democratic January 3, 2023 January 3, 2025
    U.S. House Florida District 24 Frederica S. Wilson Democratic January 3, 2013 January 3, 2025
    U.S. House Florida District 25 Debbie Wasserman Schultz Democratic January 3, 2023 January 3, 2025
    U.S. House Florida District 26 Mario Diaz-Balart Republican January 3, 2023 January 3, 2025
    U.S. House Florida District 27 Maria Elvira Salazar Republican January 3, 2021 January 3, 2025
    U.S. House Florida District 28 Carlos Gimenez Republican January 3, 2023 January 3, 2025


    State legislative maps

    See also: Florida State Senate and Florida House of Representatives

    Florida comprises 40 state Senate districts and 120 state House districts. State senators are elected every four years in partisan elections. State representatives are elected every two years in partisan elections. To access the state legislative district maps approved during the 2020 redistricting cycle, click here.[38]

    Redistricting by cycle

    Redistricting after the 2020 census

    See also: Redistricting in Florida after the 2020 census

    Florida was apportioned 28 seats in the U.S. House of Representatives. This represented a net gain of one seat as compared to apportionment after the 2010 census.[39]

    Enacted congressional district maps

    See also: Congressional district maps implemented after the 2020 census

    On September 2, 2023, Leon County Circuit Court Judge J. Lee Marsh struck down enacted North Florida congressional districts and ordered the Legislature to redraw district boundaries.[40] On June 2, 2022, the Florida Supreme Court had declined to block Florida's enacted congressional map, which Governor Ron DeSantis (R) signed into law on April 22.[41] This map took effect for Florida's 2022 congressional elections.

    The Florida First District Court of Appeal had reinstated the congressional district boundaries on May 20, overruling Leon County Circuit Court Judge Layne Smith's temporary hold on the map.[42][43] On May 11, Smith issued an order declaring Florida's enacted congressional map unconstitutional, saying, "The enacted map is unconstitutional under the Fair District amendment. It diminishes African-Americans’ ability to elect the representative of their choice." Smith also said a map drawn by a court-appointed special master should be substituted for the enacted map in the 2022 elections.[44] The plaintiffs in the case filed an emergency appeal with the Florida Supreme Court on May 23, 2022, seeking a hold on the enacted congressional map.[45]

    DeSantis signed the original congressional map into law on April 22, 2022.[46] The map bill was proposed and approved by the Florida State Legislature during a special session called for the purposes of redistricting. The Florida State Senate voted 24-15 to approve the map on April 20, and the Florida House of Representatives voted 68-34 to approve the map on April 21.[47][48]

    This was the second congressional map bill approved by the state legislature. DeSantis vetoed the first on March 29. Republican leaders in the legislature said on April 11 that they would wait to receive a map from DeSantis to support.[49] DeSantis submitted a map to the legislature on April 13, which became the enacted map.[50]

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

    Florida Congressional Districts
    until January 2, 2023

    Click a district to compare boundaries.

    Florida Congressional Districts
    starting January 3, 2023

    Click a district to compare boundaries.


    Reactions

    When DeSantis vetoed the initial map bill he wrote in a memo that "Congressional District 5 [Lawson's district] in both the primary and secondary maps enacted by the Legislature violated the Equal Protection Clause of the Fourteenth Amendment to the U.S. Constitution because it assigns voters primarily on the basis of race but is not narrowly tailored to achieve a compelling state interest."[51] Florida Politics's Jacob Ogles wrote of the enacted map, "The most controversial change DeSantis made in his map, this new CD 4 really stands in as the replacement to the Lawson seat. [...] The Black population in Jacksonville gets cleaved in half by the St. Johns River after DeSantis vetoed a map drawn by the Florida House that created a Duval-only Black seat."[52]

    State Rep. Tracie Davis (D) said "You hate when we use the word disenfranchisement. You turn your back. You look the other way. But you have to realize that is exactly what this is: Gutting, now-CD 4 … leaves us simply without representation. It simply means that the Black population in Florida that lives north of the I-4 corridor, their voices will be diluted. Their power in this process simply washed away."[53] State Rep. Dotie Joseph (D) criticized the partisan makeup of the map, saying, "They basically stacked the deck 20-8 in favor of Republicans, so this allows this power-hungry GOP to continue to ignore the needs of the people of Florida by cheating."[54]

    Rep. Randy Fine (R) supported the enacted map, saying "When we guarantee that a group of people gets to select the candidate of their choice, what we’re saying is we are guaranteeing those who aren’t a part of that group gets no say."[55] Rep. Kaylee Tuck (R) said, "[DeSantis] publicly submitted maps, which is something that anybody can do. He’s allowed to do it. Every single member of the public was allowed to do it. And just because it’s different, doesn’t mean it’s bad. Just because it’s different, doesn’t mean it’s wrong. It’s just different. The process was thorough, it was transparent. It was open. It was complete. It was constitutional. And it was good."[53]

    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.[56] This data was compiled by Daily Kos Elections.[57]

    2020 presidential results by Congressional district, Florida
    District 2022 district Political predecessor district
    Joe Biden Democratic Party Donald Trump Republican Party Joe Biden Democratic Party Donald Trump Republican Party
    Florida's 1st 33.0% 65.3% 32.4% 65.9%
    Florida's 2nd 44.0% 55.0% FL-02: 32.0%
    FL-05: 67.0%    		 FL-02: 62.7%
    FL-05: 36.2%
    Florida's 3rd 42.4% 56.5% 42.8% 56.0%
    Florida's 4th 46.0% 52.7% FL-02: 32.0%
    FL-05: 67.0%    		 FL-02: 62.7%
    FL-05: 36.2%
    Florida's 5th 41.5% 57.3% 38.9% 59.9%
    Florida's 6th 37.7% 61.4% 40.8% 58.3%
    Florida's 7th 46.7% 52.2% 54.6% 44.2%
    Florida's 8th 40.6% 58.3% 40.6% 58.3%
    Florida's 9th 58.2% 40.8% 53.0% 46.1%
    Florida's 10th 65.3% 33.5% 62.0% 37.0%
    Florida's 11th 44.1% 55.0% 33.8% 65.4%
    Florida's 12th 35.1% 63.9% 41.0% 57.9%
    Florida's 13th 46.1% 52.9% 51.5% 47.4%
    Florida's 14th 59.0% 39.8% 57.2% 41.6%
    Florida's 15th 47.9% 51.0% --- ---
    Florida's 16th 45.1% 54.0% 45.5% 53.6%
    Florida's 17th 41.6% 57.6% 35.9% 63.3%
    Florida's 18th 38.1% 60.9% 45.2% 53.7%
    Florida's 19th 39.1% 60.2% 39.6% 59.7%
    Florida's 20th 75.9% 23.5% 77.3% 22.1%
    Florida's 21st 45.0% 54.4% 45.5% 53.9%
    Florida's 22nd 58.5% 40.9% 58.2% 41.2%
    Florida's 23rd 56.3% 43.1% 57.1% 42.3%
    Florida's 24th 74.3% 25.2% 75.4% 24.0%
    Florida's 25th 59.7% 39.7% 58.3% 41.2%
    Florida's 26th 40.6% 58.9% 38.2% 61.2%
    Florida's 27th 49.6% 49.9% 51.3% 48.1%
    Florida's 28th 46.5% 52.9% 46.9% 52.5%

    Enacted state legislative district maps

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

    On March 3, 2022, the Florida Supreme Court approved new legislative maps drawn by the Florida State Legislature. These maps took effect for Florida's 2022 legislative elections.

    The maps were passed by the legislature as a joint resolution. The Florida State Senate voted 34-3 to approve the bill on January 20, and the Florida House of Representatives voted 77-39 to approve the bill on February 2.[58] Since the maps were passed as a joint resolution, they did not require the signature of Gov. Ron DeSantis (R) to become law. After the legislature approved the maps, they submitted them to Attorney General Ashley B. Moody (R), who then petitioned the Florida Supreme Court to review the maps on February 9.[59][60]

    State Senate map

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

    Florida State Senate Districts
    until November 7, 2022

    Click a district to compare boundaries.

    Florida State Senate Districts
    starting November 8, 2022

    Click a district to compare boundaries.

    State House map

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

    Florida State House Districts
    until November 7, 2022

    Click a district to compare boundaries.

    Florida State House Districts
    starting November 8, 2022

    Click a district to compare boundaries.


    Reactions

    Following the legislative approval of the maps, Senate President Wilton Simpson (R) said, "Thank you to this body for the professionalism we brought to the process this year with redistricting. We can and should be very proud of the work we’ve done here today and we’ll see if the courts are equally as proud." State Rep. Geraldine Thompson (D) criticized the House map, saying "While we won’t show retrogression in terms of fewer minority seats, at the same time, unfortunately we won’t show progression — progress in terms of the participation of minority populations in this chamber."[61]

    Redistricting after the 2010 census

    See also: Redistricting in Florida after the 2010 census

    Congressional redistricting, 2010

    Following the 2010 United States Census, Florida gained two congressional seats. In November 2010, voters approved two separate constitutional amendments establishing that congressional and state legislative districts must meet the following criteria (Amendment 6 applied to congressional districts; Amendment 5 applied to legislative districts):[62][63]

    “ [Districts] may not be drawn to favor or disfavor an incumbent or political party. Districts shall not be drawn to deny racial or language minorities the equal opportunity to participate in the political process and elect representatives of their choice. Districts must be contiguous. Unless otherwise required, districts must be compact, as equal in population as feasible, and where feasible must make use of existing city, county and geographical boundaries.[10] ”
    —Florida Division of Elections

    On February 9, 2012, the Republican-controlled state legislature approved new congressional lines. On February 16, 2012, the plan was signed into law.

    Legal challenges

    See also: Florida Congressional District Boundaries, Amendment 6 (2010)
    • On February 9, 2012, the map's opponents filed suit "challenging the congressional plan on state constitutional grounds, including violations of state prohibitions on partisan and racial gerrymandering, and requirements of compactness and adherence to political boundaries."
    • On July 10, 2014, Florida Circuit Court Judge Terry P. Lewis found that "districts 5 and 10 were drawn in contravention" of the state constitution, "thus making the redistricting map unconstitutional as drawn." Lewis specified that Districts 5 and 10 "were the product of [prohibited] intent to benefit a political party or incumbent." Lewis required that these two districts be redrawn (as well as any districts impacted by the redrawing of the aforementioned). The court ordered that the state legislature convene a special session to draft a new map.[64][65]
    “ Republican political consultants or operatives did, in fact, conspire to manipulate and influence the redistricting process...They made a mockery of the Legislature’s proclaimed transparency and open process of redistricting by doing all of this in the shadow of that process, utilizing the access it gave them to the decision makers, but going to great lengths to conceal from the public their plan and their participation in it.[10] ”
    —Judge Terry P. Lewis[66]
    Florida Supreme Court
    • On August 22, 2014, Lewis approved the new map. The map's challengers, "a group of individual voters and groups including the League of Women Voters of Florida and Common Cause Florida," appealed the newly approved map to the Florida Supreme Court, arguing that "the changes made by the legislature ... were superficial and did not cure the fundamental flaws" in the original map.[64][67]
    • On July 9, 2015, the Florida Supreme Court overturned the circuit court's decision to approve the remedial map, ruling that the trial court's "finding of unconstitutional intent" called for "a more meaningful remedy commensurate with the constitutional violations it found." The court specified that at least eight districts must be redrawn. The districts identified by the state supreme court included the following: District 5, District 13, District 14, District 21, District 22, District 25, District 26, and District 27. The court ruled 5-2 on the matter. Justice Barbara Pariente wrote the court's majority opinion.[68][69][70][71] Richard Pildes, a professor of constitutional law at New York University, wrote the following in an analysis for Election Law Blog:[72]
    “ A major basis for today’s Florida Supreme Court decision is that the Florida legislature wrongly believed or purported to believe that the Voting Rights Act required raising the population of black voters to certain high levels. Relying on the Supreme Court’s decision this Term in the Alabama racial-gerrymandering cases, the Florida court found that the VRA did not require raising the black populations to these levels. The Florida court concluded that the Republican legislature had done this for partisan political purposes, i.e., as a way to pack Democratic voters into a few districts and limit their power elsewhere. Because Florida’s Constitution now bans partisan gerrymandering, as a result of a voter initiative, these districts therefore were in violation of Florida law.[10] ”
    —Richard Pildes
    • Congressional elections in 2012 and 2014 took place under the congressional map approved in 2012. The state supreme court ordered that a new map be adopted and implemented for the 2016 election.[64][73]
    • On August 21, 2015, the Florida State Legislature adjourned a special two-week session without adopting a new congressional district map. This marked the legislature's third redistricting attempt. Governor Rick Scott (R) said that he would not convene another special session. As a result, it fell to a Florida trial judge to "choose a House or Senate [proposed] map, solicit other options, or create his own."[74][75]
    • On December 2, 2015, the Florida Supreme Court granted final approval to a new congressional district map. The map was "drawn by a coalition led by the League of Women Voters, Common Cause of Florida, and several Democrat-leaning individuals, and approved by Leon County Circuit Court Judge Terry Lewis." The state supreme court upheld the remedial map by a 5-2 decision. An image of this map can be accessed here.[76]

    State legislative redistricting, 2010

    On February 9, 2012, the state legislature approved a state legislative redistricting plan via joint resolution. The Florida Supreme Court approved the state House map, but rejected the state Senate map. The legislature revised the state Senate map on March 27, 2012, and it was approved by the state supreme court.

    Legal challenges

    On September 5, 2012, the League of Women Voters of Florida filed suit challenging the state Senate district map "on state constitutional grounds, including violations of state prohibitions on partisan gerrymandering, and requirements of compactness and adherence to political boundaries." The state filed a series of motions to dismiss in 2012 and 2013, but these were ultimately denied. The plaintiffs filed an amended complaint on April 15, 2015.[64][77]

    In autumn 2015, the Florida State Senate requested that the trial court appoint a redistricting expert to draw new state Senate district maps. On November 13, 2015, circuit court judge George Reynolds rejected this request, saying, "It appears to me that we just don't have enough time left to engage in any process, other than the one we are currently on. I do that with some reluctance because I could use all the help that I can get in making this decision." Reynolds ordered that the trial, scheduled to begin on December 14, 2015, go on as scheduled. In addition, Reynolds ordered that proposed district maps be submitted to the court by November 18, 2015.[78][79]

    On December 21, 2015, Reynolds approved a new state Senate district map. The adopted remedial map was proposed by "a coalition of voting rights groups, including the League of Women Voters of Florida." The remedial map can be accessed here.[80][81]

    State legislation and ballot measures

    Redistricting legislation

    DocumentIcon.jpg See state election laws

    The following is a list of recent redistricting bills that have been introduced in or passed by the Florida state legislature. To learn more about each of these bills, click the bill title. This information is provided by BillTrack50.

    Note: Due to the nature of the sorting process used to generate this list, some results may not be relevant to the topic. If no bills are displayed below, no legislation pertaining to this topic has been introduced in the legislature recently.

    Redistricting ballot measures

    See also: Redistricting measures on the ballot and List of Florida ballot measures

    Ballotpedia has tracked the following ballot measure(s) relating to redistricting in Florida.

    1. Florida Legislative District Boundaries, Amendment 5 (2010)
    2. Florida Congressional District Boundaries, Amendment 6 (2010)
    3. Florida Single-Member Districts and Reapportionment Commission, Amendment 3 (1978)
    4. Florida Legislature Redistricting, Amendment 1 (1964)
    5. Florida Legislative Seats, Amendment 5 (1956)
    6. Florida Legislature Reapportionment, Amendment 1 (1959)
    7. Florida Legislature Redistricting, Amendment 1 (1962)
    8. Florida Bay and Washington Counties Senatorial District, Amendment 5 (1952)
    9. Florida Monroe County Senatorial District, Amendment 6 (1952)
    10. Florida State Senate Redistricting, Amendment 3 (1948)
    11. Florida Redistricting, Amendment 6 (1942)
    12. Florida Redistricting, Amendment 4 (1924)
    13. Florida Legislature Size, Amendment 4 (1922)
    14. Florida Redistricting, Amendment 2 (1916)
    15. Florida Legislative Representation, Amendment 1 (1900)
    16. Florida Apportionment of Legislature, Amendment 2 (1944)

    Political impacts of redistricting

    Competitiveness

    There are conflicting opinions regarding the correlation between partisan gerrymandering and electoral competitiveness. In 2012, Jennifer Clark, a political science professor at the University of Houston, said, "The redistricting process has important consequences for voters. In some states, incumbent legislators work together to protect their own seats, which produces less competition in the political system. Voters may feel as though they do not have a meaningful alternative to the incumbent legislator. Legislators who lack competition in their districts have less incentive to adhere to their constituents’ opinions."[82]

    In 2006, Emory University professor Alan Abramowitz and Ph.D. students Brad Alexander and Matthew Gunning wrote, "[Some] studies have concluded that redistricting has a neutral or positive effect on competition. ... [It] is often the case that partisan redistricting has the effect of reducing the safety of incumbents, thereby making elections more competitive."[83]

    In 2011, James Cottrill, a professor of political science at Santa Clara University, published a study of the effect of non-legislative approaches (e.g., independent commissions, politician commissions) to redistricting on the competitiveness of congressional elections. Cottrill found that "particular types of [non-legislative approaches] encourage the appearance in congressional elections of experienced and well-financed challengers." Cottrill cautioned, however, that non-legislative approaches "contribute neither to decreased vote percentages when incumbents win elections nor to a greater probability of their defeat."[84]

    In 2021, John Johnson, Research Fellow in the Lubar Center for Public Policy Research and Civic Education at Marquette University, reviewed the relationship between partisan gerrymandering and political geography in Wisconsin, a state where Republicans have controlled both chambers of the state legislature since 2010 while voting for the Democratic nominee in every presidential election but one since 1988. After analyzing state election results since 2000, Johnson wrote, "In 2000, 42% of Democrats and 36% of Republicans lived in a neighborhood that the other party won. Twenty years later, 43% of Democrats lived in a place Trump won, but just 28% of Republicans lived in a Biden-voting neighborhood. Today, Democrats are more likely than Republicans to live in both places where they are the overwhelming majority and places where they form a noncompetitive minority."[85]

    State legislatures after the 2010 redistricting cycle

    See also: Margin of victory in state legislative elections

    In 2014, Ballotpedia conducted a study of competitive districts in 44 state legislative chambers between 2010, the last year in which district maps drawn after the 2000 census applied, and 2012, the first year in which district maps drawn after the 2010 census applied. Ballotpedia found that there were 61 fewer competitive general election contests in 2012 than in 2010. Of the 44 chambers studied, 25 experienced a net loss in the number of competitive elections. A total of 17 experienced a net increase. In total, 16.2 percent of the 3,842 legislative contests studied saw competitive general elections in 2010. In 2012, 14.6 percent of the contests studied saw competitive general elections. An election was considered competitive if it was won by a margin of victory of 5 percent or less. An election was considered mildly competitive if it was won by a margin of victory between 5 and 10 percent. For more information regarding this report, including methodology, see this article.

    There were 14 competitive elections for the Florida House of Representatives in 2012, compared to four in 2010. There were 10 mildly competitive state House races in 2012, compared to two in 2010. This amounted to a net gain of 18 competitive elections.


    Recent news

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

    Redistricting in Florida - Google News

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 All About Redistricting, "Why does it matter?" accessed April 8, 2015
    2. ↑ 2.0 2.1 2.2 2.3 Indy Week, "Cracked, stacked and packed: Initial redistricting maps met with skepticism and dismay," June 29, 2011
    3. ↑ 3.0 3.1 3.2 3.3 The Atlantic, "How the Voting Rights Act Hurts Democrats and Minorities," June 17, 2013
    4. ↑ 4.0 4.1 4.2 4.3 Redrawing the Lines, "The Role of Section 2 - Majority Minority Districts," accessed April 6, 2015
    5. ↑ In the Circuit Court of the Second Judicial Circuit, In and for Leon County, Florida, "Black Voters Matter Capacity Building Inst., Inc., et al v. Byrd," September 2, 2023
    6. ↑ In the Circuit Court of the Second Judicial Circuit, In and for Leon County, Florida, "Black Voters Matter Capacity Building Inst., Inc., et al v. Byrd," September 4, 2023
    7. ↑ Florida Politics, "Florida appeals court ruling tossing congressional map," September 5, 2023
    8. ↑ The Heritage Guide to the Constitution, "Election Regulations," accessed April 13, 2015
    9. ↑ Brookings, "Redistricting and the United States Constitution," March 22, 2011
    10. ↑ 10.0 10.1 10.2 10.3 10.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    11. ↑ Brennan Center for Justice, "A Citizen's Guide to Redistricting," accessed March 25, 2015
    12. ↑ The Constitution of the United States of America, "Article 1, Section 2," accessed March 25, 2015
    13. ↑ 13.0 13.1 13.2 13.3 13.4 13.5 13.6 All About Redistricting, "Where are the lines drawn?" accessed April 9, 2015
    14. ↑ 14.0 14.1 14.2 14.3 FairVote, "Redistricting Glossary," accessed April 9, 2015
    15. ↑ All About Redistricting, "Who draws the lines?" accessed June 19, 2017
    16. ↑ Encyclopædia Britannica, "Gerrymandering," November 4, 2014
    17. ↑ Congressional Research Service, "Congressional Redistricting and the Voting Rights Act: A Legal Overview," April 13, 2015
    18. ↑ The Wall Street Journal, "Supreme Court to Consider Limits on Partisan Drawing of Election Maps," June 19, 2017
    19. ↑ The Washington Post, "Supreme Court to hear potentially landmark case on partisan gerrymandering," June 19, 2017
    20. ↑ Supreme Court of the United States, "Gill v. Whitford: Decision," June 18, 2018
    21. ↑ Election Law Blog, "Breaking: SCOTUS to Hear NC Racial Gerrymandering Case," accessed June 27, 2016
    22. ↑ Ballot Access News, "U.S. Supreme Court Accepts Another Racial Gerrymandering Case," accessed June 28, 2016
    23. ↑ Supreme Court of the United States, "Cooper v. Harris: Decision," May 22, 2017
    24. ↑ The Washington Post, "Supreme Court to hear challenge to Texas redistricting plan," May 26, 2015
    25. ↑ The New York Times, "Supreme Court Agrees to Settle Meaning of ‘One Person One Vote,'" May 26, 2015
    26. ↑ SCOTUSblog, "Evenwel v. Abbott," accessed May 27, 2015
    27. ↑ Associated Press, "Supreme Court to hear Texas Senate districts case," May 26, 2015
    28. ↑ SCOTUSblog, "The new look at 'one person, one vote,' made simple," July 27, 2015
    29. ↑ Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission: Brief for Appellants," accessed December 14, 2015
    30. ↑ Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission," April 20, 2016
    31. ↑ The New York Times, "Court Skeptical of Arizona Plan for Less-Partisan Congressional Redistricting," March 2, 2015
    32. ↑ The Atlantic, "Will the Supreme Court Let Arizona Fight Gerrymandering?" September 15, 2014
    33. ↑ United States Supreme Court, "Arizona State Legislature v. Arizona Independent Redistricting Commission: Opinion of the Court," June 29, 2015
    34. ↑ The New York Times, "Supreme Court Upholds Creation of Arizona Redistricting Commission," June 29, 2015
    35. ↑ Yale Law School, The Avalon Project, "Voting Rights Act of 1965; August 6, 1965," accessed April 6, 2015
    36. ↑ 36.0 36.1 All About Redistricting, "Florida," accessed April 22, 2015
    37. ↑ Florida Constitution, "Article III, Sections 20-21," accessed April 22, 2015
    38. ↑ The Florida Senate, "Redistricting 2012-2014," accessed April 22, 2015
    39. ↑ United States Census Bureau, "2020 Census Apportionment Results Delivered to the President," April 26, 2021
    40. ↑ Tampa Bay Times, "Judge rules against DeSantis in challenge to congressional map," September 2, 2023
    41. ↑ Florida Politics, "Florida Supreme Court declines to hear challenge to congressional map ahead of Midterms," June 2, 2022
    42. ↑ Orlando Sentinel, "Florida appeals court reinstates DeSantis’ congressional map," May 20, 2022
    43. ↑ Florida District Court of Appeal, First District, "Secretary of State Laurel Lee v. Black Voters Matter, et al.," May 20, 2022
    44. ↑ NBC News, "Florida judge says he’ll block DeSantis' congressional redistricting map," May 11, 2022
    45. ↑ Florida Supreme Court, "Black Voters Matter, et al. v. Cord Byrd, Florida Secretary of State," May 23, 2022
    46. ↑ Florida Politics, "Gov. DeSantis signs his congressional map into law," April 22, 2022
    47. ↑ Florida Politics, "Florida Senate passes Gov. DeSantis’ congressional map," April 20, 2022
    48. ↑ Florida Politics, "Legislature approves Gov. DeSantis’ controversial congressional redistricting map," April 21, 2022
    49. ↑ Tampa Bay Times, "Florida Legislature won’t draft new redistricting map, deferring to DeSantis," April 11, 2022
    50. ↑ Florida Politics, "Gov. DeSantis submits congressional redistristing plan critics contend is ‘partisan gerrymandering’," April 14, 2022
    51. ↑ Florida Office of the Governor, "Memorandum Re: Constitutionality of CS/SB 102, An Act Relating to Establishing the Congressional Districts of the State," March 29, 2022
    52. ↑ Florida Politics, "Tour every congressional district on Florida’s new congressional map," April 25, 2022
    53. ↑ 53.0 53.1 CBS Miami, "Florida House Redistricting Plan Passes As Democrats Protest," April 21, 2022
    54. ↑ CBS Miami, "Florida Legislative Black Caucus Fights Back Against Gov. DeSantis’ Redistricting Map," April 22, 2022
    55. ↑ Click Orlando, "Central Florida lawmakers protest governor’s redistricting map before it passes in House," April 21, 2022
    56. ↑ Political predecessor districts are determined primarily based on incumbents and where each chose to seek re-election.
    57. ↑ Daily Kos Elections, "Daily Kos Elections 2020 presidential results by congressional district (old CDs vs. new CDs)," accessed May 12, 2022
    58. ↑ Florida State Senate, "CS/SJR 100: Joint Resolution of Apportionment," accessed March 3, 2022
    59. ↑ Florida Politics, "Florida Legislature approves redistricting maps for Senate and House," February 3, 2022
    60. ↑ Florida Politics, "Ashley Moody petitions court on legislative maps as congressional redistricting continues to pitter," February 9, 2022
    61. ↑ The Derrick, "Florida Legislature approves its own redistricting maps as DeSantis seeks court ruling," February 3, 2022
    62. ↑ Florida Division of Elections, "Standards for Legislature to Follow in Legislative Redistricting," accessed April 22, 2015
    63. ↑ Florida Division of Elections, "Standards for Legislature to Follow in Congressional Redistricting," accessed April 22, 2015
    64. ↑ 64.0 64.1 64.2 64.3 All About Redistricting, "Litigation in the 2010 cycle," accessed April 22, 2015
    65. ↑ Law 360, "Voter Coalition Appeals Fla. Court's OK of Redrawn Maps," August 29, 2014
    66. ↑ Politico, "Judge tosses Florida congressional map," July 10, 2014
    67. ↑ Law 360, "Voter Coalition Appeals Fla. Court's OK of Redrawn Maps," August 29, 2014
    68. ↑ Tampa Bay Times, "Florida Supreme Court orders new congressional map with eight districts to be redrawn," July 9, 2015
    69. ↑ Florida Supreme Throws Out Congressional Map, Orders Battleground Districts Redrawn," July 9, 2015
    70. ↑ Florida Supreme Court, "League of Women Voters of Florida v. Detzner: Opinion," July 9, 2015
    71. ↑ Ballot Access News, "Florida Supreme Court Orders Legislature to Redraw U.S. House Districts," July 9, 2015
    72. ↑ Election Law Blog, "The Alabama Redistricting Cases and Today’s Decision Invalidating Eight Congressional Districts in Florida," July 9, 2015
    73. ↑ Law 360, "Voter Coalition Appeals Fla. Court's OK of Redrawn Maps," August 29, 2014
    74. ↑ The Miami Herald, "Florida Legislature ends special session with no agreement on new congressional districts," August 21, 2015
    75. ↑ NPR, "Judge To Redraw Florida's Congressional Maps After Legislature Fails To Reach Deal," August 21, 2015
    76. ↑ Miami Herald, "Florida Supreme Court approves congressional map drawn by challengers," December 2, 2015
    77. ↑ CBS Miami, "Senate Redistricting Battle Looms," July 8, 2015
    78. ↑ The Miami Herald, "Judge orders Senate redistricting trial to move forward," November 13, 2015
    79. ↑ Tampa Bay Times, "Judge orders Florida Senate redistricting trial to move forward," November 13, 2015
    80. ↑ Florida Politics, "Judge selects plaintiffs’ map in Senate redistricting case," December 21, 2015
    81. ↑ Florida Politics, "New state Senate seats renumbered," January 5, 2016
    82. ↑ The Daily Cougar, "Redistricting will affect November election," October 16, 2012
    83. ↑ The Journal of Politics, "Incumbency, Redistricting, and the Decline of Competition in U.S. House Elections," February 2006
    84. ↑ Polity, "The Effects of Non-Legislative Approaches to Redistricting on Competition in Congressional Elections," October 3, 2011
    85. ↑ Marquette University Law School Faculty Blog, "Why Do Republicans Overperform in the Wisconsin State Assembly? Partisan Gerrymandering Vs. Political Geography," February 11, 2021
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