In the discussion that follows, we focus on the case of congressional districting rather than on districting in general. Although we proceed in this manner for the sake of clarity, it is also true that no single, all-purpose normative theory of electoral mechanics will cover every case of democratic representation, from county commissions to mosquito control districts to sovereign legislatures. We do not claim that one can generalize our argument to every sort of election to which the VRA might apply. Yet we think our argument does approximate a theory of general application.
Daniel D. Polsby & Robert D. Popper,
Ugly: An Inquiry Into the Problem of Racial Gerrymandering Under the Voting Rights Act,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol92/iss3/4