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petitioned the U.S. Supreme Court to grant ... - Election Law Blog

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22aAppendix Dcomplying with <strong>the</strong> Gingles I precondition-<strong>to</strong> show that ageographically compact district in which Hispanics willmake up a majority of <strong>the</strong> eligible voters can be drawnin Irving.a. Criteria for Drawing Illustrative DistrictsMr. Ely constructed <strong>the</strong> illustrative districts consistentwith <strong>the</strong> traditional principles of drawing districts andwell-established demographic considerations. (TrialTr. vol. 1, 52-55, Feb. 17, 2009.) First, districts shouldgenerally have equal <strong>to</strong>tal population. For municipalities,<strong>the</strong> population size of each district should not deviatefrom <strong>the</strong> o<strong>the</strong>rs by more than 10%. The illustrativedistricts created by Mr. Ely all contained within 1% of<strong>the</strong> ideal population based on <strong>the</strong> 2000 Census. (Pl.’sPretrial Br. 11.) Second, districts must comply with legalrequirements, such as <strong>the</strong> Equal Protection Clause. Andthird, districts should be drawn consistent with existingofficial political boundaries (along city or county lines) andinformal geographic boundaries, such as neighborhoods orcommunities that share a common interest. Here, Mr. Elyconstructed illustrative districts using undivided Censusblocks and used recognizable boundaries such as streets.(Pl.’s Ex. 1, at 6.)(4) Illustrative District A had an estimated HCVAPin 2008 of 58.0%. (Id. at Ex. 5, at 4.)(5) Illustrative District B had an estimated HCVAPin 2008 of 56.5%. (Id. at Ex. 8.)(6) Illustrative District C had an estimated HCVAPin 2008 of 55.6%. (Id. at Exs. 15 and 17.)

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