Commentary...
Commentary
Judicial Review of Electoral Mechanics After Crawford
May 6 (Chris Elmendorf)Last December, I published an article that advanced two descriptive claims about nature of the Supreme Court’s Storer-Burdick (or “electoral mechanics”) jurisprudence. The first claim, which I thought perhaps so obviously true as to be uninteresting, was that in spite of the Court’s nominal rejection of “litmus paper tests” in favor of open-ended balancing in this area, the Court’s decisions actually manifest a strong preference for simple, formal threshold tests by which challenged requirements may be sorted into the twin categories of presumptively permissible and presumptively impermissible (and subjected to lax review or strict scrutiny accordingly). My second claim, which I thought more provocative, was that Burdick misleads where it indicates that that scrutiny levels are to vary with the severity of the burden on the plaintiff’s rights of political participation.
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Information and Analysis
2005 Post-Election Redistricting Reform Developments
Ohio
- Redistricting in the Wake of Legislative Downsizing in Rhode Island (June 21, 2006)
- HJR 13: Did Ohio Miss a Rare Opportunity? (May 30, 2006)
- H.J.R. No. 13-as introduced
- Sub. H.J.R. No. 13 (Republican proposal as amended, defeated by Democrats on Thursday, May 25, 2006)
- H.J.R. No. 6 (original Democratic proposal, reintroduced by Republicans, and defeated by Democrats in subsequent vote on Thursday, May 25, 2006)
- 2005 Election Results
News Articles
- Election officials again consider vendor switch for voter registration system, The Lima News (7/12/06)
- The stolen election of 2004, The Columbus Free Press (7/11/06)
- U.S. offers Euclid way to avoid suit, Cleveland Plain Dealer (6/22/2006)
- Redistricting plans rejected, Columbus Dispatch (5/26/2006)
- Redistricting issues remain unsettled, Cleveland Plain Dealer (5/26/2006)
- Redistrict proposals rejected, Dayton Daily News (5/25/2006)
- Partisanship takes over on map-drawing resolution, Akron Beacon Journal (5/25/2006)
- Democrats may block overhaul of districting, Columbus Dispatch (5/25/2006)
- Husted wants House to vote on plan for Ohio redistricting, WCPO (5/24/2006)
- Redistricting bill has critics, Columbus Dispatch (5/24/2006)
- Senate won't act on redistricting plan before break, Akron Beacon Journal (5/22/2006)
- Senate won't hurry overhaul plan for political district drawing, Akron Beacon Journal (5/22/2006)
- Democrats won't help with redistricting reform, Toledo Blade (5/12/2006)
- House supports district reform, Cincinnati Post (5/5/2006)
- GOP proposes new redistricting panel, Cleveland Plain Dealer (5/5/2006)
- Redistricting reform, round 2, Columbus Dispatch (5/5/06)
- Republicans unveil redistricting plan, Youngstown Vindicator (5/5/06)
- Legislative districts may be fall ballot issue, Dayton Daily News (5/5/06)
- House wants new commission to draw districts, Akron Beacon Journal (5/4/06)
- Highlights of the House redistricting bill, Akron Beacon Journal (5/4/06)
- Proposal would subtract illegal immigrants from redistricting count, Akron Beacon Journal (3/7/2006)
- Ohio redistricting issue nears compromise, Toledo Blade (3/3/2006)
- Ohio lawmakers consider ballot issue for redrawing districts, Toledo Blade (1/20/2006)
- Speaker returns to redistricting issue, Columbus Dispatch (1/20/2006)
- Redistricting plan being considered, Dayton Daily News (1/20/2006)
- Leaders eye redistricting compromise, Toledo Blade (11/15/2005)
- Husted, Democrats in talks on district plan, Dayton Daily News (11/15/2005)
- Ohio Republicans to Pursue Bipartisan Election Reform (11/10/2005)
Opinions/Commentaries
- Reformers face skeptics in both parties on map-drawing, Dayton Daily News (6/23/2006)
- GOP redistricting plan put compactness ahead of competitiveness, Dayton Daily News (6/15/2006)
- Passing map-drawing reform is like herding cats, Dayton Daily News (6/9/2006)
- A way to rescue redistricting reform (Edward B. Foley, 6/6/2006)
- Politics trumping reform of system, News-Herald (6/6/2006)
- Ooops! Incompetent Ohio Democrats, RedState (6/5/2006)
- Oops!, Athens News (6/5/2006)
- Partisanship trumps a good idea, Cleveland Plain Dealer (6/1/2006)
- Two down, one to go, Cincinnati Enquirer (5/31/2006)
- Legislators find, lose harmony, Cleveland Plain Dealer (5/30/2006)
- Blame the Democrats, Akron Beacon Journal (5/29/2006)
- Reform won't wait, Columbus Dispatch (5/28/2006)
- Republicans play power politics with TEL issue, show savvy on redistricting, Dayton Daily News (5/28/2006)
- Dems deserting voters when reform is doable, Dayton Daily News (5/27/2006)
- Ohio Dems kill redistricting proposal, Equal Vote Blog (5/25/2006)
- Is bipartisan redistricting reform achievable?, Free and Fair (5/19/2006)
- The new Ohio redistricting proposal, Equal Vote Blog (5/17/2006)
- Democrats might not be up to doing the right thing on redistricting, Columbus Dispatch (5/14/2006)
- Map-drawing plan must be fair, Cincinnati Enquirer (5/12/2006)
- A better idea, Columbus Dispatch (5/10/2006)
- Editorial: Empty words? Calls for change don't match records, The Post Online (5/9/2006)
- Electoral laments in major and minor keys, Free and Fair (5/9/2006)
- Reform? No hurry now, Cleveland Plain Dealer (5/8/2006)
- Redistricting requires quality data, Toledo Blade (1/29/2006)
- Issues lack of foresight was troubling, Toledo Blade (11/14/2005)
- Much needed redistricting reform isn't in the cards for Ohio, Columbus Dispatch (11/13/2005)
General
News Articles
- Kidd calls for independent redistricting commission, Associated Press (08/30/06)
- First salvos prepared for statehouse redistricting battles, Stateline.org (08/24/06)
- South Dakota Ordered to Comply with Voting Rights Act, ACLU (08/22/06)
- Ask The Author: Jeff Rosen, Part II, SCOTUSblog (08/22/06)
- Ask The Author: Jeff Rosen, Part I, SCOTUSblog (08/21/06)
- Election Law at the High Court: Big Cases Leave Little Footprints, Law.com (08/18/06)
- State redistricting proposal succumbs in legislative limbo, The San Francisco Chronicle (08/18/06)
- Democrats, Union Gearing Up for 2012 Redistricting, CQ Politics (08/18/06)
- Don't let redistricting reform die, The Mercury News (08/16/06)
- Colorado Redistricting Lawsuit Dismissed, Associated Press (08/14/06)
- Democrats Get a Boost From Court Redistricting, Austin Chronicle (08/11/06)
- The Redistricting Myth, The Democratic Strategist (08/03/06)
- Gop Lawmakers Push To Keep Redistricting Powers, Gwinnett Daily Post (08/03/06)
- Federal Judge Protects Eligible Voters In Washington, Brennan Center For Justice (08/01/06)
- U.S. Senate approves voter rights extension, The New York Times (7/21/06)
- NAACP vows to fight vote suppression, People's Weekly World Newspaper (7/20/06)
- LULAC offers its own redistricting map, News 8 Austin, (7/19/06)
- Linking eased term limits to redistricting equals real reform, The Desert Sun (7/19/06)
- Austin City Council To Discuss Congressional Redistricting, Associated Press (7/19/06)
- Austin leaders consider redistricting options, Austin Business Journal (7/18/06)
- Chances of Voting Rights Act renewal dim, Associated Press (7/12/06)
- The right to vote still at stake, The New York Daily News (7/12/06)
- Voter registration issues cloud elections, USA Today (7/10/06)
- New election districts for lawmakers not likely, The Shreveport Times (7/10/06)
- Redistricting feeds 'toxic' politics, USA Today (7/10/06)
- A better method for redistricting, Fort Wayne Star Telegram (7/10/06)
- Democrats Not Eager To Emulate Texas's Redistricting, Washington Post (7/5/06)
- GOP candidates pledge bipartisan redistricting, Indianapolis Star (6/21/2006)
- PA lawmaker unveils redistricting proposal, Public Radio Capitol News (6/15/2006)
- Rethought: redrawing plans to redistrict, Newsday (6/14/2006)
- Ex-staffer: redistricting needs overhaul, Gwinnett Daily Post (6/8/2006)
- Hearings slated on New York Legislative redistricting, New York Times (6/6/2006)
- 'Political middle' lost in legislature with redistricting, Washington Times (6/5/2006)
- State Rep. to appeal redistricting ruling to U.S. Supreme Court, Columbus Ledger-Enquirer (6/4/2006)
- Some confused about redistricting, Eufaula Tribune (5/26/2006)
- Three voters file another lawsuit in redistricting case, Columbus Ledger-Enquirer (5/23/2006)
- Judges uphold legislative districts, Mobile Register (5/23/2006)
- Bonacic bill to push redistricting reform, Daily Star (5/22/2006)
- Wentworth pushes plan for redistricting commission, Fort Worth Star Telegram (5/19/2006)
- Judicial redistricting to happen in 2007, Wheeling Intelligencer (5/19/2006)
- Redistricting decision lies with Purdue, Athens Exchange (5/12/2006)
- Group wants new state redistricting, Utica Observer Dispatch (5/8/2006)
- Reformers target state redistricting, Rochester Democrat and Chronicle (5/8/2006)
- Drawing the line: redistricting reform, Gotham Gazette (5/8/2006)
- Judges reject effort to halt redistricting, Gainesville Times (5/3/2006)
- Georgia considers redistricting reform, Gwinnett Daily Post (4/30/2006)
- Redistricting case stays with judge after challenge fails, Mohave Daily News (4/24/2006)
- Groups call for nonpartisanship in drawing district lines, New York Times (4/21/2006)
- Plan for Carroll election is OK'd, Baltimore Sun (4/20/2006)
- Carroll to ask courts to define districts, Baltimore Sun (4/12/2006)
- Court blocks redistrict vote, OKs ballot to ban gay unions, Orlando Sentinel (3/24/2006)
- Florida Supreme Court rejects proposed referendum on creating redistricting panel, Sun-Sentinel (3/24/2006)
- District boundaries shift with the times, Duluth News Tribune (3/18/2006)
- State legislatures: the race for redistricting starts now, CQPolitics.com (3/14/2006)
- Redistricting ruled out, Connecticut Post (3/7/2006)
- Justices seem to back redistricting, The Argus (3/2/2006)
- Justices express skepticism in Texas redistricting case, Baltimore Sun (3/2/2006)
- Republicans shoot down redistricting reform, Salt Lake Tribune (2/14/2006)
- Florida: several legislators ask Supreme Court to block propose initiative on redistricting,
Votelaw (2/10/2006) - Lawmakers seek to keep redistricting off ballot, Lakeland Ledger (2/10/2006)
- High court considers redistricting amendment, Orlando Sentinel (2/10/2006)
- Court to hear ballot proposal for redistricting, Daytona Beach News (2/9/2006)
- District boundaries spark debate, Bradenton Herald (2/7/2006)
- Sanford to redraw its voting districts, Sun-Sentinel (2/1/2006)
- House OKs new districts, Red and Black (2/1/2006)
- House lawmakers allow Senate redistricting despite objections, Macon Telegraph (2/1/2006)
- Gerrymandering called rife in redistricting plan, Joongang Ilbo (1/30/2006)
- Redistricting measure heads to high court, Tallahassee Democrat (1/28/2006)
- House OKs redistricting change, Indianapolis Star (1/27/2006)
- Redistricting coming to FL?, National Journal (1/26/2006)
- Independent redistricting bill gaining momentum in General Assembly, Cape Gazette (1/26/2006)
- Garton pans redistricting bill, Louisville Courier-Journal (1/26/2006)
- Group: redistricting measure has signatures, Orlando Sentinel (1/25/2006)
- Democrats protest Athens redistricting, Macon Telegraph (1/23/2006)
- Bill would create new body to redistrict, Fort Wayne News Sentinel (1/20/2006)
- District map plan advances, Fort Wayne Journal Gazette (1/20/2006)
- Committee may define legislative districts, Louisville Courier-Journal (1/20/2006)
- It's tough to separate politics, redistricting, Indianapolis Star (1/20/2006)
- Senate pushes map change that would divide Athens, Macon Telegraph (1/13/2006)
- GOP plan: new body should draw maps, Indianapolis Star (1/10/2006)
- High court observers see redistricting case as pivotal, Houston Chronicle (12/14/2005)
- Will court draw the line on remaps?, Denton Record-Chronicle (12/14/2005)
- Redistricting question taking a new direction, Newton TAB (12/14/2005)
- High court will review Texas redistricting case, Cleveland Plain Dealer (12/13/2005)
- Court has splintered history on political boundary drawing, Wilkes Barre Times-Leader (12/12/2005)
- A better council map, Fort Wayne Journal Gazette (12/12/2005)
- When it comes to maps, politicians will be politicians, Dallas Morning News (12/8/2005)
- Democrats seek probe of redistricting plan, San Francisco Chronicle (12/2/2005)
- Justice saw Texas districting as illegal, Washington Post (12/2/2005)
- District drawing still ripe for reform, Advertiser-Tribune (11/27/2005)
- Spitzer calls for nonpartisan districting, New York Times (11/22/2005)
- Spitzer vows to end fixed redistricting, New York Daily News (11/22/2005)
- Spitzer takes on Legislature in reform platform, New York Newsday (11/22/2005)
- '06 election already rigged, Fort Wayne Journal Gazette (11/18/2005)
- Redistricting defeats, Washington Post (11/14/2005)
- Falling off the political path of the straight and narrow, Macomb Daily (11/13/2005)
- Two setbacks in fair redistricting, Ledger (11/13/2005)
Opinions/Commentaries
- Democracy Breaks Out in CT, Yahoo! News (08/14/06)
- Redistricting and the Courts, Washington Post (7/14/06)
- Redistricting ruling deals a blow to American democracy, Baltimore Sun (7/5/2006)
- Improving Voter Participation, The Century Foundation (6/30/2006)
- It's broke, fix it: our legislative districting, Pocono Record (6/23/2006)
- Right on redistricting, Newsday (6/19/2006)
- Don't throw redistricting stones at Voting Rights Act, Atlanta Journal Constitution (6/14/2006)
- Drawing for districts, Atlanta Journal Constitution (6/12/2006)
- Gerrymandering polarizes legislatures, Roanoke Times (6/7/2006)
- The gerrymandering myth, New Republic (6/1/2006)
- Prison-based gerrymandering, New York Times (5/20/2006)
- Cheating the voters, Orlando Sentinel (5/19/2006)
- Redistricting reform is good for the voters, Albany Times Union (5/15/2006)
- Blake: redistricting revisited, Rocky Mountain News (5/3/2006)
- The gerrymander that ate America, Slate (4/17/2006)
- Redistricting only part of the answer to one-party rule, Canon City Daily Record (4/14/2006)
- Drawing the lines, Daily Press (3/8/2006)
- Drawing lines on lines, Washington Post (3/8/2006)
- The fight for redistricting, New York Sun (3/7/2006)
- Roadmap to fair redistricting, Daytona Beach News-Journal (3/7/2006)
- To improve ethics, retool redistricting process, Robertson County Times (2/16/2006)
- Legislative redistricting: Utah should create a bipartisan panel to redraw boundaries, Salt Lake
Tribune (2/15/2006) - Line drawing, Tallahassee Democrat (2/11/2006)
- Make elections more competitive with redistricting, San Jose Mercury News (2/9/2006)
- Voters can decide on solid redistricting plan, Dayton Beach News-Journal (2/8/2006)
- Why did redistricting reform fail in California and Ohio in 2005? New survey research provides great data and a lot of insight, Election Updates (2/7/2006)
- Maybe lawmakers should be more afraid of voters, Milwaukee Journal Sentinel (2/4/2006)
- Gerrymander curbs long overdue, York Dispatch (2/2/2006)
- Senate must draw line on partisanship, Indianapolis Star (1/30/2006)
- Time to draw the line on redistricting, Indianapolis Star (1/26/2006)
- Redistricting without the politics? We can only hope, Marion Chronicle Tribune (1/24/2006)
- Seeking simpler districts, Fort Wayne News Sentinel (1/18/2006)
- Redistricting: let panel draw maps, Fort Wayne Journal Gazette (1/15/2006)
- Question for Judge Alito: What about one person, one vote?, Civilrights.org (1/3/2006)
- Redistricting case presents opportunity for Court, Foxnews.com (1/3/2006)
- Redistrict once a decade, Hartford Courant (12/15/2005)
- Overdue review: Supreme Court hearing on Texas redistricting will provide a barometer to measure partisanship on the high court, Houston Chronicle (12/14/2005)
- When drawing lines means holding keys, The Republican (12/13/2005)
- Playing with the process? , Fort Worth Star-Telegram (12/12/2005)
- The winner-take-all endgame, TomPaine.com (12/9/2005)
- Remembering Gilman and the evils of redistricting, New York Times Herald-Record (12/9/2005)
- Evidence of political manipulation at the Justice Department: how Tom DeLay's redistricting plan avoided Voting Rights Act Disapproval, Findlaw's Legal Commentaries (12/6/2005)
- Gerrymander slander, The National Review (12/6/2005)
- The Texas gerrymander, Centre Daily Times (12/6/2005)
- Kick the foxes from the henhouse: reform redistricting now, AScribe (12/5/2005)
- The system isn't 'broke', so don't fix it, Centre Daily Times (12/5/2005)
- Spitzer's idea could undo redistricting wrongs on state level, The Journal News (12/1/2005)
- Competitive elections, redistricting are vital, Milwaukee Journal Sentinel (11/28/2005)
- Returning power to the people, New York Daily News (11/27/2005)
- Unfair system, Orlando Sentinel (11/27/2005)
- Voters restrict their own choices, Indianapolis Star (11/22/2005)
- Redistricting reform can minimize politics, Albany Times Union (11/22/2005)
- Tug-of-war in redistricting getting worse, Jackson Clarion Ledger (11/20/2005)
- Redistricting reform: how best to tackle ultra-safe districts, OpEd News (11/18/2005)
- Alone with J...Gerrymandering prevails, Decatur Daily Democrat (11/18/2005)
- Anything but straight, Falls Church News-Press (11/182005)
- Gerrymandering leaves centrists without a voice in government, Beaver County Times (11/17/2005)
- Redistricting dance, Albany Times Union (11/16/2005)
- Redistricting reform after the failed Ohio and California initiatives, The Brookings Institution Brookings Briefings (11/15/2005)
- Citizens must drive electoral reform, Roll Call (11/15/2005)
- Redistricting reform, Winston-Salem Journal (11/15/2005)
- Did U.S. elections kill redistricting reform?, Bloomberg (11/15/2005)
- Initiatives' defeats deal a blow to electoral reform, Mercury News (11/15/2005)
- Gotta be a better way, Star-Telegram (11/14/2005)
- District changes fall to those in office, Northeast Mississippi Daily Journal (11/14/2005)
- For election reform, a heartening defeat, New York Times (11/11/2005)
- Next time, start with the people, Balkinization (11/10/2005)
California
- 2005 Election Results
- Re-Drawing Lines: A Public Interest Analysis of California’s 2006 Redistricting Reform Proposals, Center for Governmental Studies (August 2006)
News Articles
- Don't rush to fix Legislature, The Orange County Register (7/21/06)
- Coalition Identifies Ingredients for New Redistricting Plan, Letter & Press Release,
Commonwealth Club of California (7/19/06) - Deal to Ease Term Limits Draws Legislators' Interest, Los Angeles Times (7/15/06)
- Redistricting rides again, The Argus (6/27/2006)
- Redistricting measure back before lawmakers, Contra Costa Times (6/26/2006)
- Redistricting a likely issue for State Senate, The Argus (6/19/2006)
- Redistricting resurfaces, Monterey County Herald (6/19/2006)
- Legislature may drop its redistricting role, Contra Costa Times (6/19/2006)
- Lawmakers may give up district-drawing power, Long Beach Press-Telegram (6/19/2006)
- New redistricting plan advancing, Los Angeles Daily News (6/19/2006)
- State Senate likely to revisit redistricting issue this week, San Francisco Chronicle (6/18/2006)
- If redistricting is real, it'll emulate state high court, Sacramento Bee (6/12/2006)
- State Senate vote on redistricting reform expected today, California Progress Report (6/1/2006)
- Bipartisans coalition urges governor, legislators to support redistricting reform, California Chronicle (5/31/2006)
- 66% support Ashburn redistricting reform proposal, California Chronicle (5/11/2006)
- Committee to hold hearing on redistricting plan, Daily Independent (4/18/2006)
- Redistricting plan a long shot, but a promise is a promise, Los Angeles Times (3/23/2006)
- Redistricting panel nears reality, Daily Democrat (3/17/2006)
- New bid to carve districts survives, Sacramento Bee (3/16/2006)
- Committee passes measure to change California's redistricting process, Scripps Howard News Service (3/15/2006)
- Redistricting reform legislation passes key hurdle, California Chronicle (3/15/2006)
- Hearing on Ashburn's proposed redistricting amendment set for Wednesday morning, Daily Independent (3/15/2006)
- Lawmakers still donating to anti-Prop. 77 campaign, Scripps Howard News Service (2/17/2006)
- Legislators reviving redistricting proposals, Contra Costa Times (2/17/2006)
- Supreme Court says redistricting measure was rightfully on ballot, San Francisco Chronicle (2/17/2006)
- Redistricting reform plans could make California's political landscape somewhat more competitive, UC Berkeley News (2/7/2006)
- Redistricting reform may yet emerge from Legislature, San Jose Mercury News (1/31/2006)
- Redistricting may return to ballot, Contra Costa Times (1/29/2006)
- Redistricting returns to the drawing board, San Jose Mercury News (1/28/2006)
- Lawmakers call for creation of citizens panel, San Jose Mercury News (1/27/2006)
- Legislators say reform is on the way for political maps, Daily Breeze (1/16/2006)
- Redistricting backers renew effort to change process, San Francisco Chronicle (1/5/2006)
- Another remap plan is offered, Sacramento Bee (1/4/2006)
- Coalition plans new California redistricting initiative, Sacramento Bee (1/3/2006)
- Daniel Weintraub: redistricting might live to see another day, Sacramento Bee (11/29/2005)
- California: redistricting reform; So, what's next?, Policy Today (11/22/2005) - Article begins on page 8
- Prop. 77 furor fading; hopes for reform rekindled, Capitol Weekly (11/22/2005)
- Redrawing legislative lines may become group effort, Tri-Valley Herald (11/14/2005)
- Redistricting reform fights for comeback after election defeat, Daily Breeze (11/14/2005)
- 'Reform' groups to keep fighting, San Gabriel Valley Tribune (11/13/2005)
- Election: leaders talk about redistricting reform, Daily Democrat (11/12/2005)
Opinions/Commentaries
- Reform redistricting, Contra Costa Times (6/27/2006)
- Lawmakers poised to give up key power? Let's hope, Desert Sun (6/26/2006)
- Lawmakers should lead on redistricting, San Jose Mercury News (6/19/2006)
- Redrawing voting lines on the table, Appeal-Democrat (6/15/2006)
- Court created best way to redraw state's district lines, The Argus (6/13/2006)
- Redistricting is back on the table, OCRegister (6/12/2006)
- A case for redistricting reform, California Progress Report (6/2/2006)
- Cavala against "redistricting reform", California Progress Report (6/1/2006)
- Harnessing the will for political change in California, San Francisco Chronicle (2/28/2006)
- State desperately needs redistricting reform, Pasadena Star News (2/15/2006)
- Could redistricting be the answer, Tracy Press (2/11/2006)
- Redistricting one cure for California's dysfunctional status quo, Scripps Howard News Service (2/7/2006)
- Holding Democrats to their promises, Sacramento Bee (1/29/2006)
- Remember redistricting, San Francisco Chronicle (1/29/2006)
- How to draw the line, Pasadena Star News (1/26/2006)
- As we see it: state redistricting needed, Santa Cruz Sentinel (1/20/2006)
- Guest editorial, Desert Dispatch (1/9/2006)
- Mathematical solution to redistricting possible, Ventura County Star (1/8/2006)
- Texas decision could aid California voters, Whittier Daily News (12/14/2005)
- Gerrymander review, Los Angeles Daily News (12/13/2005)
- Guest Commentary: Voters select politicians, not vice versa, Ridgecrest Daily Independent (11/23/2005)
- Will California's leaders follow through on redistricting?, San Francisco Chronicle (11/18/2005)
- Back to the drawing board, San Francisco Chronicle (11/18/2005)
- California needs a Citizens' Assembly, Santa Monica Mirror (11/17/2005)
- Redistricting defeat raw deal for voters, San Antonio Express (11/14/2005)
- Redistrict? Just do it, Long Beach Press-Telegram (11/13/2005)
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