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16At the same time, immigrant populations havecentralized in specific neighborhoods and localities withinthese states. See Albert Saiz, Immigration and theNeighborhood, 3 American Economic Journals: Policy169-188 (May 2011). For example, “Orange County’s LittleSaigon—like any Little Italy, Chinatown, Little Tokyo,or Little Havana—is, for its own residents and for manyoutsiders, a symbol of the maturity of a distinct Americanimmigrant experience, the carving out of a place of one’sown[.]” Douglas M. Padgett, Religion, Memory, andImagination in Vietnamese California 77 (2007). Theseimmigrant population centers tend to cluster in a state’slargest cities. See Passel, supra, 10. As a consequence,when jurisdictions make redistricting decisions basedon total population, this centralization of non-citizenssignificantly increases the likelihood that states andlocalities will form districts with vastly disproportionatenumbers of eligible voters. 6It should come as no surprise, then, that this issue hasarisen across the country. See, e.g., Jamin B. Raskin, LegalAliens, Local Citizens, 141 U. Pa. L. Rev. 1391, 1463 (1993)(explaining that after Takoma Park, Maryland completedits redistricting process, “its new wards had equalnumbers of residents, as required by law, but that some6. This issue also arises in other contexts. Districts can bemalapportioned on the basis of voting age population even withoutconsidering citizenship. See Daly, 93 F.3d at 1212; see also SanfordLevinson, One Person, One Vote: A Mantra in Need of Meaning, 80N.C. L. Rev. 1269, 1287 n.80 (2002) (“California’s current District29 contains only 13.9% population under the age of eighteen years,whereas more than a third (36.2%) of the population of District 37… is under the age of [eighteen].”). How to treat such disparitiesis likewise an important issue. See Levinson, supra, 1288