Partisan Gerrymandering in the Post-Bandemer Era.

Last year, the Supreme Court decided a case dealing purely with the issue of partisan gerrymandering for the first time. 1 The Court unequivocally ruled gerrymandering to be justiciable, but failed to assemble a majority behind any standard. Consequently the task of developing a measure of partisan gerrymandering has become urgent. In an earlier article2 we argued that the main obstacle to effective court action against partisan gerrymandering was the lack of a clear, precise measure of partisan gerrymandering.J We developed a specific political measure and demonstrated it in a case study. Recognizing the difficulty of measuring gerrymandering, we urged other scholars to address the issue. In the ensuing years, there has been much written on the subject.4 Since the Court has opened the