Abstract
Regardless of who draws the redistricting plan in a state with numerous districts, there are always complaints about the outcome. We suggest that the inherent conflicts among the traditional redistricting criteria make any multi-district plan subject to criticism and vulnerable to litigation. In particular, the mandates to respect communities of interest while drawing competitive districts are frequently irreconcilable. This is because many communities of interest are themselves lopsidedly partisan, and including them whole or undiluted will impede the pathway to achieving an even partisan division in a district's electorate. Examples drawn from North Carolina and Pennsylvania serve to illustrate the constraints that map drafters face, regardless of for whom they are employed.
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