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Ground War
 Ground War
Courts, Commissions, and the Fight over Partisan
Gerrymanders
NICHOLAS GOEDERT
 Oxford University Press is a department of the University of Oxford. It furthers the
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Published in the United States of America by Oxford University Press
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© Oxford University Press 2022
All rights reserved. No part of this publication may be reproduced, stored in a retrieval
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You must not circulate this work in any other form and you must impose this same
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Library of Congress Control Number: 2021925678
ISBN 978–0–19–762663–4 (pbk.)
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ISBN 978–0–19–762665–8 (epub.)
DOI: 10.1093/oso/9780197626627.001.0001
For Sumin and Arcadia
 Contents

Acknowledgments

1. Introduction: A Tale of Two Gerrymanders

2. The Theory behind Gerrymandering
3. Legal Developments and Standards in Partisan Gerrymandering
4. Gerrymandering and Competitive Elections
5. Measuring Historical Bias: Historically Weighted Efficiency Gap
6. Bias and Responsiveness in Partisan Maps
7. Bias and Responsiveness in Nonpartisan Maps
8. Conclusion: The Road to Reform

Appendix
Notes
References
Index
 Acknowledgments

This book has been over a decade in the making, during which the
entire field of redistricting took many unexpected twists and turns,
requiring rewrites and restructurings that sometimes seemed
endless. As with any project of such scope and duration, it would not
have been possible without the help and support of many people
along the way. Those listed here represent only a small sample.
I am first indebted to the late Prof. Roy Schotland, whose
mentorship in election law seminars at Georgetown led me down the
career path of studying the empirical implications of election
institutions. I am thankful to the Princeton University Department of
Politics for their initial encouragement of my project in the early
stages, especially my dissertation advisor, Brandice Canes-Wrone;
my other advisors over the course of my graduate career, including
Nolan McCarty, Aaron Meirowitz, Chris Achen, and Tali Mendelberg;
and all of the American Politics graduate students and faculty who
deepened my development as a scholar, both in my coursework and
at the weekly research seminars where I was given the chance to
present my own ideas and delve into those of my colleagues.
I would like to thank the Department of Political Science, the
College of Liberal Arts and Human Sciences, and the Policy
Destination Area at Virginia Tech for lending their institutional
support for both this project and my research over the past five
years. I am especially grateful to the empiricist group within our
department, including Aaron Brantley, Karen Hult, Eric Jardine,
Caitlin Jewitt, Jason Kelly, and Karin Kitchens, for their valuable
feedback on my manuscript prospectus and several of the analytical
chapters. Additional thanks to Robert Hildebrand for help with
rendering the book’s graphics and maps, and Conrad Briles for
proofreading.
 I am also grateful for the engagement and encouragement of the
participants of a manuscript workshop I held in 2019. Daniel Bowen,
Keith Gaddie, Alex Keena, Nolan McCarty, and Nick Stephanopoulos
each provided thorough critiques of my initial draft that proved
invaluable toward getting me over the hump toward final
submission. And I would like to thank my editor, David McBride, for
his patience and persistence in seeing the book through to review
and publication during a very difficult time.
Most important, I am grateful for the unconditional love and
support of my family throughout my life and during the years spent
on this project, especially my wonderful parents, Jim and JoAnn.
I dedicate this book to my beautiful, kind, and generous wife,
Sumin, who has encouraged me in all aspects of my life every day
for the past five years, and my daughter, Cady, whose birth provided
the ultimate deadline to finish my writing and whose miraculous
growth provided inspiration for me to see it through to the end.
 1
Introduction
A Tale of Two Gerrymanders

Partisan gerrymandering, the drawing of legislative district lines to

deliberately advantage one political party, has been present and
controversial in American politics since before the ratification of our
Constitution. Throughout the past several decades, the propriety,
legality, and effectiveness of partisan gerrymanders has bounced
back and forth in a wide-ranging debate among legislators, scholars,
judges, and citizens.
Yet over the course of the past decade, a series of legislative,
electoral, and judicial events have given this issue a prominence it
has never before seen, especially as it applies to the U.S. House of
Representatives. In the 2010 midterm elections, a concerted effort
by Republicans to win state legislative seats (“Project REDMAP,”
described in detail in Daley 2016) gave one party unprecedented
control over the redistricting process in the majority of large swing
states, including Florida, Michigan, North Carolina, Ohio,
Pennsylvania, and Virginia, following the 2010 national census.
These partisan gerrymanders aided in a strikingly “antimajoritarian”
outcome in the 2012 congressional elections, in which Republicans
won a large majority of congressional seats despite winning fewer
congressional votes than Democratic candidates at the national level.
The intuitive unfairness of these results led to a burst of litigation
against partisan gerrymandering in all of the affected states and
others over the course of the next several years. In 2015 through
2018, reform advocates won a series of victories in the state courts
and lower federal appellate courts, leading to brief optimism that the
ultimate solution might lie in the court system. But this optimism
was crushed in the summer of 2019, when the U.S. Supreme Court
held in Rucho v. Common Cause that partisan gerrymandering claims
were a political question that the federal courts should have no role
in deciding.
This is a book about the harms caused by the gerrymandering of
the U.S. Congress and the role that courts and voters should play to
solve them. Justice Roberts’s majority opinion in Rucho, essentially
foreclosing the possibility that federal courts can remedy
partisanship in the drawing of legislative maps, was deeply
disappointing to advocates of redistricting reform. But the decision
was not unreasonable or unprincipled. Indeed, the issues of political
fairness involved in districting are nuanced and multidimensional and
do not lend themselves to judgment by a simple, one-size-fits-all
standard. A gerrymander may be viewed through an entirely
different lens across two different states, two different voters, or two
different election cycles. The pathologies of partisan
gerrymandering, and indeed legislative control of the redistricting
process itself, are real. But they are not confined to an easily
measurable bias in an election result. For these reasons, this book
argues that the more appropriate actors to address the fairness of a
map (or the process of drawing a map) are the voters within each
state, not the U.S. courts.
Although gerrymandering has received the greatest attention in
the most recent decade, the problems presented by districting and
the effectiveness of solutions can be most clearly drawn by
contrasting two cases from the early 2000s: a partisan map in
Pennsylvania that landed in the Supreme Court and a bipartisan
compromise in California that led to citizen revolt at the ballot box.

Pennsylvania, 2001–2010
For the first half of the 2000s, Pennsylvania Republicans might have
believed they had found the perfect gerrymander. At the beginning
of the decade, the Republican-controlled legislature, with assistance
from national party figures such as Karl Rove and Chairman Tom
Davis of the National Republican Congressional Committee, crafted a
map “designed so effectively to change political outcomes in
Pennsylvania that it began to be referred to by Democratic state
legislators as a ‘massacre’ and by a local Harrisburg newspaper as
‘the most partisan congressional gerrymander of this young century,
and among the worst in the last several decades of the earlier
millennium’ ” (Douglas 2016, 199–200). After yielding a 12–7 GOP
majority in the elections seventeen months earlier, the map was
upheld in 2004 by the U.S. Supreme Court in Vieth v. Jubelirer. In
this case, a 5–4 conservative majority held that no standard yet
existed that would allow the courts to fairly adjudicate the harms
caused by partisan gerrymanders.
Yet that same map must not have seemed so perfect to
Republicans in 2006, when Democrats regained control of Congress
by flipping thirty-one seats that included four Republican-crafted
districts in Pennsylvania. While this was a strong night for Democrats
on many fronts, their gains were not spread equally across the
country: Democrats also gained two seats drawn by bureaucrats in
Iowa and two seats drawn by a nonpartisan commission in Arizona,
but the balance of the delegation in California, where the map had
been approved by both parties working in close concert, remained
unchanged.
The Pennsylvania map was aggressive in seeking to maximize the
Republican advantage, eliminating a district in each of Pittsburgh
and Philadelphia and placing six Democrats in districts with other
incumbents. But in drawing such a bold map, the governing party
did not anticipate the partisan shifts that their state would
experience over the decade, particularly as voters in suburban
Philadelphia increasingly identified as Democrats. Few of the
Republican-held seats could be called truly safe: George W. Bush
received 52% of the vote or less in seven of these twelve seats in
the 2000 election. So the Republicans, relying on the moderate party
brand remaining viable in many of the suburban swing seats, were
buried under the Democratic tide of 2006. Four incumbents were
defeated that year, some by scandal and others simply by changing
demographics, with a fifth losing in 2008.
Republicans in Pennsylvania, attempting to win more than two-
thirds of the seats in an evenly matched state, gambled on
assembling swing districts that they hoped to win merely by running
moderates or popular incumbents. So it is unsurprising that things
did not go as planned for Pennsylvania Republicans when the tide
turned against them. Had the mapmakers not been so willing to take
risks, dividing pockets of moderates into Republican districts in order
to eliminate as many Democratic seats as possible, some of their
doomed incumbents might have survived the massacres of 2006 and
2008.
Pennsylvania voters were able to reverse the result of the partisan
gerrymander at the ballot box in 2006 and 2008. But their failure to
achieve relief from the courts in 2004 also ensured that this reversal
was short-lived. The Republican wave of 2010 restored the map to a
five-seat GOP advantage, and this majority was further exaggerated
by another Republican gerrymander in 2012. That year, Republicans
in Pennsylvania won thirteen of the state’s eighteen seats despite
losing the congressional popular vote. Again, Pennsylvania voters
turned to the courts, but this time, the state courts. In 2018’s
League of Women Voters v. Pennsylvania, opponents of partisan
gerrymandering finally won a major court victory. The Pennsylvania
State Supreme Court reversed the congressional map on state
constitutional grounds, and Democrats achieved an even split of the
delegation under the court-drawn map in the 2018 midterm
elections. Nevertheless, this decision narrowly applied only to
Pennsylvania, and when the U.S. Supreme Court rejected a series of
challenges to partisan gerrymandering in Whitford, Rucho, and
Benisek, nationwide relief in the court system remained elusive.
Because of the ambiguous lessons we might draw from it, the
Pennsylvania congressional map of the early 2000s has been a
touchstone allowing many scholars to arrive at very different
conclusions about partisan gerrymandering. In their book
Gerrymandering in America, McGann et al. (2016) argue that the
success of Pennsylvania’s map at the Supreme Court in the Vieth
case caused states to feel less constrained about drawing partisan
maps in the next decade, leading to much more aggressive and
successful partisan gerrymanders after the 2010 census. But in his
book Drawing the Lines, Seabrook (2017) uses the backfire of the
same Pennsylvania map in 2006 and 2008 as evidence of inherent
electoral constraints that limit the ultimate effectiveness of partisan
maps.

California, 2001–2010
At the same time that Pennsylvania lawmakers were drawing the
partisan maps that would win in court but backfire at the ballot box,
California legislators were drawing a map that was much less legally
controversial yet arguably just as pernicious and more effective.
During the 1990s, a court-ordered plan kept the partisan balance
close in California for most of the decade, but leftward trends finally
caught up to Republicans in 2000, when Democrats flipped four
Republican districts in that cycle to take a 32–20 advantage in seats.
California gained one seat in the 2000 census, and Democrats held
control of state government. Many expected the party to use this
power to significantly expand their majority.
But the Democrats did not use this opportunity to draw an
aggressively partisan map. Instead, they felt pressure from both the
right and the left to be much more cautious. If they drew a map to
gain as many seats as possible, they risked a Republican-backed
ballot proposition to change the redistricting process and the
prospect of serious primary challenges from state legislators forced
to retire due to legislative term limits. Thus, leaders of the state
congressional delegations of both parties reached an agreement to
draw a map that would ensure the reelection of almost every
incumbent. Over the objections of almost half the Democrats in the
state legislature, the plan passed with roughly even support from
both parties.
While one might expect a map produced by bipartisan
compromise to be a story of triumph for pluralist and deliberative
democracy, those involved in the process describe something else
entirely. Congressman Alan Lowenthal (2019, 4), a California
Assembly member at the time, recounts:

I found this process to be very upsetting. More reminiscent of the Tammany

Hall political machine than twenty-first-century governing, incumbent elected
officials held private meetings behind closed doors and literally selected their
own voters. Those officials prioritized political expediency and incumbency
protection over any criteria that considered natural boundaries, compactness,
or cohesive communities of interests.

In a review of recent California reforms, Eric McGhee (2015, 7)

described the maps as “a set of plans that largely preserved the
status quo by making districts less competitive, especially for
Congress, while seeming to satisfy no one but the authors.”
The map worked exactly as expected. In the 2002 general
election, every incumbent won with at least 58% of the vote, and
the Democrats held a 33–20 advantage in the delegation. And over
the course of the decade, these seats remained safe for incumbents.
Out of 265 congressional elections that took place in California under
this map, the incumbent party was defeated only once, and
Democrats had gained just one additional seat by 2009. Even in the
face of the Republican tide in 2010, Democrats held on to all thirty-
four of these seats, a sign that the map was resilient to tides in both
directions.
So, unlike in Pennsylvania, large swings in public sentiment seen
in the second half of the 2000s were unable to subvert the
intentions of the legislature in drawing California’s congressional
map. And also unlike in Pennsylvania, California citizens did not turn
to the court system for a solution but instead used their direct power
of referendum, and did so repeatedly. Even in the absence of
unilateral partisan motivations, “good government organizations
began to see redistricting as a question of effective representation,
[and] argued that the lack of competition in the new districts
protected extreme partisans in the legislature” (McGhee 2015, 7). An
initial reform effort led by Governor Arnold Schwarzenegger to place
redistricting in the hands of retired judges narrowly failed in 2005.
But in 2008 and 2010, a series of ballot initiatives successfully
transformed California’s electoral process, including 2010’s
Proposition 20, which took the power to draw congressional district
lines out of the hands of the partisan state legislature and put it into
the hands of a commission. California was not the first state to
adopt a redistricting commission, but it did adopt unique selection
and deliberation procedures to encourage an unprecedented degree
of independence and citizen involvement.
The results of adopting a commission were immediately apparent,
as congressional elections became demonstrably more competitive
and responsive. California has seen triple the number of close
elections in the 2010s compared to the previous decade, and the
2018 midterms saw a dramatic disruption in the political split of the
delegation in response to strong partisan tides, as Democrats flipped
seven seats previously held by Republicans.1 At the same time,
California became a model for redistricting reform across the
country, as four states adopted redistricting commissions by ballot
referendum in 2018, many clearly borrowing procedures and criteria
for Proposition 20.

The Lessons of Pennsylvania and California

The examples from Pennsylvania and California demonstrate a clear
contrast in both the problems presented by legislative
gerrymandering and its potential solutions. The recurring
“countermajoritarian” outcomes in Pennsylvania congressional
elections show that partisan gerrymandering presents real normative
problems to the functioning of a representative democracy. Yet the
map was also ultimately responsive to the ongoing demographic
changes in the state and short-term swings in voter preferences in
successive wave elections at the end of the decade. By comparison,
the map in California was not drawn to advantage one party or the
other. But even when parties come together to draw a mutually
agreeable map, as California Democrats and Republicans did in
2001, the results can be just as normatively offensive as the worst of
partisan gerrymanders, arriving at a map that is completely immune
from changes in the makeup of the electorate or the will of the
voters.
Pennsylvania and California also show two very different avenues
for pursuing reform. Democrats in Pennsylvania went through the
federal court system and had their claim not just rejected but
rejected with such force that many argue the case incentivized even
worse partisanship going forward. Their suit did nothing to prevent
an even more egregious partisan map ten years later. Democrats
again pursued litigation, and this time finally succeeded in 2018. But
they succeeded in state court, not federal court, under narrow state
constitutional grounds that did nothing to alter the future
gerrymandering process, instead only imposing some superficial
constraints.
California’s voters chose to pursue a public referendum rather
than litigation. In doing this, they received immediate and
permanent relief through the creation of an independent redistricting
commission in 2010. While the results in Pennsylvania were only
getting worse, the results in California were strikingly better, mostly
eliminating bias in the delegation, increasing competitiveness, and
improving the congruence of representation.
These two outcomes exemplify the two major paths to
gerrymandering reform. And as this book will argue, one path has
clearly emerged as superior. Even prior to Justice Roberts shutting
the door on federal litigation in 2019, relief from the courts has
always been unpredictable, superficial, and temporary. By contrast,
nonpartisan commissions have provided enduring, structural, and
effective solutions, even in the face of partisan criticism. And
although these commissions have most often been enacted by public
referendum, potential for this sort of reform exists even where
citizen initiatives are not available. I hope that this book might
contribute to the political will to accomplish this.
 Plan of the Book
Throughout this book, I make the argument that although partisan
gerrymandering harms American democracy in several important
ways, the more realistic way to fight it lies in changing the process
at the state level by adopting nonpartisan commissions rather than
through the court system. The argument requires an understanding
of the political theory behind districting and representation, the
jurisprudential background and legal history, the empirical evidence
for the historical and recent effects of gerrymandering, and recent
political reform movements. And so it proceeds through each of
these topics as follows.
In Chapter 2, I discuss the theory of how gerrymandering works,
with emphasis on two dimensions of the issue that are sometimes
neglected. First, many equally valid yet often competing claims can
be made about the quality of one’s representation, and a map or
electoral process that responds well to one claim may fail to
accommodate others. Second, an electoral map is not static, and
resulting delegations may change dramatically over its life. So when
evaluating a map, we must anticipate the range of possible
outcomes that it may produce.
In Chapter 3, I discuss the legal arguments surrounding several
recent prominent cases on partisan gerrymandering, in each
instance trying to distill the most important claims made by the
plaintiffs into an easily or universally applicable test. I then apply
each “stylized test” to the facts of the other cases, concluding that
no single test or standard will resolve all cases in a satisfying way.
In Chapter 4, I use historical evidence from the past fifty years of
congressional elections to examine the conditions under which
partisan, nonpartisan, and bipartisan gerrymandering has
encouraged or suppressed competitive elections and partisan
turnover. Here I find that while partisan gerrymanders discourage
close competition when the national environment is close to even,
they create a lot of close elections and turnover under strong tides
averse to the gerrymandering party. In contrast, I demonstrate that
nonpartisan commissions tend to foster the most close elections,
while bipartisan agreements consistently generate the fewest,
regardless of partisan tides.
Chapters 5 through 7 use a new measure of bias and
responsiveness to show both the multiple harms created by partisan
gerrymandering in the current era and the potential for nonpartisan
commissions as a flexible solution. This measure, historically
weighted efficiency gap (HWEG), estimates bias under a wide range
of electoral conditions for any given state, leveraging national
historical election data, along with results from congressional and
statewide elections in each state. Unlike other measures in common
use, HWEG can be used to easily visualize the situations under which
any map will be most biased and/or responsive, as well as
synthesize average bias and responsiveness under a weighted
average of conditions, regardless of the state’s underlying partisan
balance. In Chapter 5, I discuss the motivation for my measurement
and detail how it is calculated, using several illustrative examples. In
Chapter 6, I apply the measurement to all partisan gerrymanders in
the 2010s decade. I find that these states all violate important
democratic norms, but not all in the same ways. Rather, partisan
gerrymanders in competitive states are severely biased when the
election is close but somewhat compensated through responsiveness
to changes in public opinion, while gerrymanders in noncompetitive
states show a more understated bias but at the cost of an almost
total lack of competitive elections under all conditions.
In Chapter 7, I apply this measure to five cases of states adopting
a more nonpartisan approach. From this, I draw two important
conclusions. First, each of these states has made a different but
deliberate decision to privilege some norms or goals over others,
such as competitiveness or geographic stability. And so the results
produced by each commission vary significantly. But each
commission state has also tended to produce mostly unbiased maps
that also promote democratic responsiveness. Thus, commissions
have largely succeeded at not only remedying the immediate harms
observed under all classes of partisan gerrymandering but also
adapting the particular preferences embodied in the political culture
of their state.
In Chapter 8, I summarize the findings of the previous chapters
but also look to the future. Specifically, I examine recent efforts by
citizens and legislatures to combat partisan gerrymandering as
possible models for action nationwide. While the likelihood for a
solution in the court system may still be dim, the prospects for
reform at the state level have never been higher. And this is not just
the more likely venue for action, but the more appropriate and
effective one.
 2
The Theory behind Gerrymandering
Drawing Districts in the United States

In almost every nation in the world with some democratic electoral

structures, representatives are chosen at least in part by dividing the
country into geographic districts. In U.S. federal elections, these
districts are the fifty states for the U.S. Senate and 435 single-
member districts contained within those states for the House of
Representatives. Elections for state legislatures are also mostly
conducted using single-member geographic districts, with a handful
of states using multimember districts for one legislative house.
As I will detail in Chapter 3, the U.S. Constitution requires that
congressional and state legislative lines be redrawn into equal
population districts following the national census that occurs every
ten years. I refer to this legally mandated process as redistricting,
and the fact that states periodically must redistrict is not in and of
itself in dispute. However, as redistricting is mostly done by the
elected branches of our state governments, several political factors
tend to seep into this process, leading invariably to conflict and
controversy. The use of the redistricting process to achieve some
political goal is generally referred to as gerrymandering. This book
deals specifically with partisan gerrymandering, which I define as the
use of redistricting to achieve the electoral goals of one political
party, such as increasing the likely number of representatives elected
from that party, or maximizing the likelihood that a party will elect a
majority of representatives.
Partisan gerrymandering has been practiced and disputed for
centuries, with state legislative gerrymandering predating the
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