Redistricting in North Dakota
 in North Dakota |
Redistricting is the process by which new congressional and state legislative district boundaries are drawn. North Dakota's one United States Representative and 141 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]
North Dakota was apportioned 1 seat in the U.S. House of Representatives after the 2020 census, the same number it received after the 2010 census.
North Dakota was apportioned one single at-large U.S. House seat, making Congressional redistricting after the 2020 census unnecessary.
The U.S. District Court of North Dakota struck down the state's legislative map on November 17, 2023, saying in its ruling in the case Turtle Mountain Band of Chippewa Indians v. the Secretary of State of North Dakota, "The Secretary is permanently enjoined from administering, enforcing, preparing for, or in any way permitting the nomination or election of members of the North Dakota Legislative Assembly from districts 9 and 15 and subdistrict 9A and 9B. The Secretary and Legislative Assembly shall have until December 22, 2023, to adopt a plan to remedy the violation of Section 2."[5] North Dakota Gov. Doug Burgum (R) signed legislation enacting the state's legislative map on November 11, 2021. Click here for more information on maps enacted after the 2020 census.
See the sections below for further information on the following topics:
- Background: A summary of federal requirements for redistricting at both the congressional and state legislative levels
- State process: An overview about the redistricting process in North Dakota
- District maps: Information about the current district maps in North Dakota
- Redistricting by cycle: A breakdown of the most significant events in North Dakota's redistricting after recent censuses
- State legislation and ballot measures: State legislation and state and local ballot measures relevant to redistricting policy
- 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.[6][7]
| “ | 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.[8] | ” |
| —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."[9][10][11]
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."[11]
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."[11]
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.
- 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.[11][12]
- 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.[11][12]
- 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.[11][12]
- 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.[11][12]
Methods
In general, a state's redistricting authority can be classified as one of the following:[13]
- 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.
- 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.
- Hybrid: In a hybrid state, the legislature shares redistricting authority with a commission.
Gerrymandering
- 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][14]
For additional background information about gerrymandering, click "[Show more]" below.
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.[15]
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.[16][17]Recent court decisions
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.
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.[18]
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.[19][20][21]
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.[22][23][24][25]
Harris v. Arizona Independent Redistricting Commission (2016)
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.[26][27][28]
Arizona State Legislature v. Arizona Independent Redistricting Commission (2015)
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.[29][30][31][32]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.[8] | ” |
| —Voting Rights Act of 1965[33] | ||
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, North Dakota was home to zero 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
Because North Dakota has only one congressional district, congressional redistricting is not necessary. The state legislature draws state legislative district boundaries. State legislative district lines are subject to veto by the governor.[34]
The North Dakota Constitution requires that state legislative districts be "compact and contiguous."[34][35]
How incarcerated persons are counted for redistricting
States differ on how they count incarcerated persons for the purposes of redistricting. In North Dakota, incarcerated persons are counted in the correctional facilities they are housed in.
District maps
Congressional districts
North Dakota comprises a single congressional district. The table below lists North Dakota's current U.S. Representative.
| Office | Name | Party | Date assumed office | Date term ends |
|---|---|---|---|---|
| U.S. House North Dakota At-large District | Kelly Armstrong | Republican | January 3, 2019 | January 3, 2025 |
State legislative maps
North Dakota comprises 47 legislative districts. Each district elects one senator and two representatives. State senators are elected every four years in partisan elections. State representatives are elected every four years in partisan elections. To access the state legislative district maps approved during the 2020 redistricting cycle, click here.
Redistricting by cycle
Redistricting after the 2020 census
North Dakota was apportioned one seat 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.[36]
Enacted congressional district maps
North Dakota was apportioned one single at-large U.S. House seat, making Congressional redistricting after the 2020 census unnecessary.
Enacted state legislative district maps
The U.S. District Court of North Dakota struck down the state's legislative map on November 17, 2023, saying in its ruling in the case Turtle Mountain Band of Chippewa Indians v. the Secretary of State of North Dakota, "The Secretary is permanently enjoined from administering, enforcing, preparing for, or in any way permitting the nomination or election of members of the North Dakota Legislative Assembly from districts 9 and 15 and subdistrict 9A and 9B. The Secretary and Legislative Assembly shall have until December 22, 2023, to adopt a plan to remedy the violation of Section 2."[5] North Dakota Gov. Doug Burgum (R) signed legislation enacting the state's legislative map on November 11, 2021.
The North Dakota House of Representatives approved the maps in a 73-18 vote on November 9, 2021, and the North Dakota State Senate approved the maps in a 40-7 vote on November 10, 2021.[37] These maps took effect for North Dakota's 2022 legislative elections.
The map was drafted by the Legislative Redistricting Committee, which had fourteen Republican members and two Democratic members. The state maintained its 47 legislative districts, but three new districts were placed near more populous areas and three districts were removed from less populous rural areas.[38]
State Senate map
Below is the state Senate map in effect before and after the 2020 redistricting cycle.
North Dakota State Senate Districts
until November 30, 2022
Click a district to compare boundaries.
North Dakota State Senate Districts
starting December 1, 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.
North Dakota State House Districts
until November 30, 2022
Click a district to compare boundaries.
North Dakota State House Districts
starting December 1, 2022
Click a district to compare boundaries.
Reactions to passage of initial maps
After signing the map, Gov. Doug Burgum (R) released a statement saying: "We appreciate the Legislature and the interim redistricting committee for their fairness, diligence and transparency as they conducted this important process, which is key to ensuring a representative democracy."[37] The Dickinson Press reported that Rep. Mike Schatz (R) said "the map is geographically absurd and [...] has been gerrymandered," with Schatz saying: "I cannot for the life of me figure out why they would make this. They’re really pushing those of us who don’t like their map into a corner, and that’s frustrating for me."[39]
Regarding the map's House subdivisions drawn to encompass the Fort Berthold reservation in District 4 and the Turtle Mountain reservation in District 9, Rep. Bill Devlin (R) said: "I firmly believe that under the federal law and the court decisions that have been established and upheld, we had to do this. We had no choice.” [40] Rep. Terry Jones (R) criticized the decision, saying: "If we leave subdistricts in this bill, we will be guilty of racial gerrymandering."[41]
Redistricting after the 2010 census
Following the 2010 United States Census, North Dakota did not add a congressional seat, rendering congressional redistricting unnecessary. On November 9, 2011, the state legislature approved a new state legislative district map. The map was signed into law that same day by Governor Jack Dalrymple.[34]
State legislation and ballot measures
Redistricting legislation
The following is a list of recent redistricting bills that have been introduced in or passed by the North Dakota 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
Ballotpedia has tracked the following ballot measure(s) relating to redistricting in North Dakota.
- North Dakota Redistricting Commission Initiative, Amendment 1 (1973)
- North Dakota State Senate Reapportioning Referendum, Amendment 3 (1960)
- North Dakota Two Congressional Districts, Referendum 1 (1960)
- North Dakota Legislative Apportionment Plan Referendum, Measure 1 (1973)
- North Dakota Legislature Composition and Compensation Referendum, Amendment 6 (1976)
- North Dakota State Apportionment and Transition Schedule Referendum, Amendment 2 (1978)
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."[42]
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."[43]
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."[44]
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."[45]
State legislatures after the 2010 redistricting cycle
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.
North Dakota was not included in this study.
Recent news
The link below is to the most recent stories in a Google news search for the terms Redistricting North Dakota. These results are automatically generated from Google. Ballotpedia does not curate or endorse these articles.
See also
- United States census, 2020
- Redistricting in North Dakota after the 2010 census
- Redistricting
- State-by-state redistricting procedures
- Majority-minority districts
- State legislative and congressional redistricting after the 2010 census
- Margin of victory in state legislative elections before and after the 2010 census
- Margin of victory analysis for the 2014 congressional elections
External links
- All About Redistricting
- Dave's Redistricting
- FiveThirtyEight, "What Redistricting Looks Like In Every State"
- National Conference of State Legislatures, "Redistricting Process"
- FairVote, "Redistricting"
Footnotes
- ↑ 1.0 1.1 All About Redistricting, "Why does it matter?" accessed April 8, 2015
- ↑ 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
- ↑ 3.0 3.1 3.2 3.3 The Atlantic, "How the Voting Rights Act Hurts Democrats and Minorities," June 17, 2013
- ↑ 4.0 4.1 4.2 4.3 Redrawing the Lines, "The Role of Section 2 - Majority Minority Districts," accessed April 6, 2015
- ↑ 5.0 5.1 U.S. District Court for the District of North Dakota, "Turtle Mountain Band of Chippewa Indians vs. Michael Howe, in his Official Capacity as Secretary of State of North Dakota," November 17, 2022
- ↑ The Heritage Guide to the Constitution, "Election Regulations," accessed April 13, 2015
- ↑ Brookings, "Redistricting and the United States Constitution," March 22, 2011
- ↑ 8.0 8.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
- ↑ Brennan Center for Justice, "A Citizen's Guide to Redistricting," accessed March 25, 2015
- ↑ The Constitution of the United States of America, "Article 1, Section 2," accessed March 25, 2015
- ↑ 11.0 11.1 11.2 11.3 11.4 11.5 11.6 All About Redistricting, "Where are the lines drawn?" accessed April 9, 2015
- ↑ 12.0 12.1 12.2 12.3 FairVote, "Redistricting Glossary," accessed April 9, 2015
- ↑ All About Redistricting, "Who draws the lines?" accessed June 19, 2017
- ↑ Encyclopædia Britannica, "Gerrymandering," November 4, 2014
- ↑ Congressional Research Service, "Congressional Redistricting and the Voting Rights Act: A Legal Overview," April 13, 2015
- ↑ The Wall Street Journal, "Supreme Court to Consider Limits on Partisan Drawing of Election Maps," June 19, 2017
- ↑ The Washington Post, "Supreme Court to hear potentially landmark case on partisan gerrymandering," June 19, 2017
- ↑ Supreme Court of the United States, "Gill v. Whitford: Decision," June 18, 2018
- ↑ Election Law Blog, "Breaking: SCOTUS to Hear NC Racial Gerrymandering Case," accessed June 27, 2016
- ↑ Ballot Access News, "U.S. Supreme Court Accepts Another Racial Gerrymandering Case," accessed June 28, 2016
- ↑ Supreme Court of the United States, "Cooper v. Harris: Decision," May 22, 2017
- ↑ The Washington Post, "Supreme Court to hear challenge to Texas redistricting plan," May 26, 2015
- ↑ The New York Times, "Supreme Court Agrees to Settle Meaning of ‘One Person One Vote,'" May 26, 2015
- ↑ SCOTUSblog, "Evenwel v. Abbott," accessed May 27, 2015
- ↑ Associated Press, "Supreme Court to hear Texas Senate districts case," May 26, 2015
- ↑ SCOTUSblog, "The new look at 'one person, one vote,' made simple," July 27, 2015
- ↑ Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission: Brief for Appellants," accessed December 14, 2015
- ↑ Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission," April 20, 2016
- ↑ The New York Times, "Court Skeptical of Arizona Plan for Less-Partisan Congressional Redistricting," March 2, 2015
- ↑ The Atlantic, "Will the Supreme Court Let Arizona Fight Gerrymandering?" September 15, 2014
- ↑ United States Supreme Court, "Arizona State Legislature v. Arizona Independent Redistricting Commission: Opinion of the Court," June 29, 2015
- ↑ The New York Times, "Supreme Court Upholds Creation of Arizona Redistricting Commission," June 29, 2015
- ↑ Yale Law School, The Avalon Project, "Voting Rights Act of 1965; August 6, 1965," accessed April 6, 2015
- ↑ 34.0 34.1 34.2 All About Redistricting, 'North Dakota," accessed April 22, 2015
- ↑ North Dakota Constitution, "Article IV, Section 2," accessed April 22, 2015
- ↑ United States Census Bureau, "2020 Census Apportionment Results Delivered to the President," April 26, 2021
- ↑ 37.0 37.1 North Dakota Office of the Governor, "Burgum signs bill to approve legislative redistricting, completing process required following 2020 census," November 11, 2021
- ↑ U.S. News and World Report, "North Dakota Legislature Approves New Redistricting Map," November 10, 2021
- ↑ The Dickinson Press, "Governor approves ND redistricting map; area lawmaker unhappy," November 11, 2021
- ↑ The Dickinson Press, "North Dakota lawmakers pass redistricting plan that could boost Native American voting power," November 10, 2021
- ↑ KX News, "North Dakota House approves legislative map with subdistricts for two reservations," November 9, 2021
- ↑ The Daily Cougar, "Redistricting will affect November election," October 16, 2012
- ↑ The Journal of Politics, "Incumbency, Redistricting, and the Decline of Competition in U.S. House Elections," February 2006
- ↑ Polity, "The Effects of Non-Legislative Approaches to Redistricting on Competition in Congressional Elections," October 3, 2011
- ↑ 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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