Thank you, Madame Chief Justice and may it please the court.

This case of Evenwel

v Abbott essentially asks the question should districts be drawn according to the
total population of that district or should congressional and state districts be drawn
by total voter population. It is the opinion of the state of Texas, represented by
Governor Abbott, would you raise you hand for the jury please Mr. Abbott. Thank
you sir, as I was saying it is the opinion of the the State of Texas and Mr. Abbott that
congressional districts should be drawn by total population. That total population
should include children, the mentally ill, felons, and most importantly the citizens of
the United States who choose not to vote. We reason that voting is a right of the
people and we encourage all citizens who are eligible to participate in our political
process, however should a citizen choose not to vote or should they be barred from
voting because of age or other factors including but not limited to criminal record
and mental illness they should not be disenfranchised when they are all certainly
affected when legislators legislate at the local state and national level.

and accepts the view that only voters or even registered voters are to be counted when
drawing district lines, children, legal residents, and people who have committed felonies or
the mentally illall of whom are certainly affected when legislators legislateare not to be
counted for apportionment purposes.
most notably in Baker v. Carr and Reynolds v. Sims, the court determined that legislative
districts had to be roughly equal in population.
nobody really has any idea how voters are to be counted, given that the censusthe best
measure we have for who lives wheredoesnt track whether youre a voter. An amicus
brief submitted by a group of former directors of the census points out that there is no
actual count of the number of voting age citizens.
Writing in 1964 the court famously noted that legislators represent people, not trees or
acres. The question the court must now decide is how to choose which people we want to
represent