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Redistricting in Ohio

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Redistricting is the process by which new congressional and state legislative district boundaries are drawn. Each of Ohio's 15 United States representatives and 132 state legislators are elected from political divisions called districts. United States senators are not elected by districts but by the states at large. District lines are redrawn every 10 years following completion of the United States Census. The federal government stipulates that districts must have nearly equal populations and must not discriminate on the basis of race or ethnicity.[1][2][3][4]

Ohio was apportioned 15 seats in the U.S. House of Representatives after the 2020 census, 1 fewer than it received after the 2010 census.

HIGHLIGHTS
  • Following the 2020 United States Census, Ohio was apportioned 15 congressional districts, one less than the number it had after the 2010 census.
  • Ohio's House of Representatives is made up of 99 districts; Ohio's State Senate is made up of 33 districts.
  • In Ohio, congressional district boundaries are set by the state legislature. State legislative district lines are drawn by a politician commission.
  • On March 2, 2022, the Ohio Redistricting Commission approved a redrawn congressional map in a 5-2 vote along party lines, meaning the map lasted for four years.[5] On March 18, the Ohio Supreme Court ruled that it did not have jurisdiction to overturn the map before the state's primary elections as part of the legal challenge that overturned the initial congressional map.[6] This map took effect for Ohio's 2022 congressional elections. On September 23, 2023, the Ohio state legislature adopted new legislative maps.[7] These maps were upheld by the Ohio Supreme Court on November 27, 2023.[8] Click here for more information on maps enacted after the 2020 census.

    See the sections below for further information on the following topics:

    1. Background: A summary of federal requirements for redistricting at both the congressional and state legislative levels
    2. State process: An overview about the redistricting process in Ohio
    3. District maps: Information about the current district maps in Ohio
    4. Redistricting by cycle: A breakdown of the most significant events in Ohio's redistricting after recent censuses
    5. State legislation and ballot measures: State legislation and state and local ballot measures relevant to redistricting policy
    6. Political impacts of redistricting: An analysis of the political issues associated with redistricting

    Background

    This section includes background information on federal requirements for congressional redistricting, state legislative redistricting, state-based requirements, redistricting methods used in the 50 states, gerrymandering, and recent court decisions.

    Federal requirements for congressional redistricting

    According to Article I, Section 4 of the United States Constitution, the states and their legislatures have primary authority in determining the "times, places, and manner" of congressional elections. Congress may also pass laws regulating congressional elections.[9][10]

    The Times, Places and Manner of holding Elections for Senators and Representatives, shall be prescribed in each State by the Legislature thereof; but the Congress may at any time by Law make or alter such Regulations, except as to the Places of chusing Senators.[11]
    —United States Constitution

    Article I, Section 2 of the United States Constitution stipulates that congressional representatives be apportioned to the states on the basis of population. There are 435 seats in the United States House of Representatives. Each state is allotted a portion of these seats based on the size of its population relative to the other states. Consequently, a state may gain seats in the House if its population grows or lose seats if its population decreases, relative to populations in other states. In 1964, the United States Supreme Court ruled in Wesberry v. Sanders that the populations of House districts must be equal "as nearly as practicable."[12][13][14]

    The equal population requirement for congressional districts is strict. According to All About Redistricting, "Any district with more or fewer people than the average (also known as the 'ideal' population), must be specifically justified by a consistent state policy. And even consistent policies that cause a 1 percent spread from largest to smallest district will likely be unconstitutional."[14]

    Federal requirements for state legislative redistricting

    The United States Constitution is silent on the issue of state legislative redistricting. In the mid-1960s, the United States Supreme Court issued a series of rulings in an effort to clarify standards for state legislative redistricting. In Reynolds v. Sims, the court ruled that "the Equal Protection Clause [of the United States Constitution] demands no less than substantially equal state legislative representation for all citizens, of all places as well as of all races." According to All About Redistricting, "it has become accepted that a [redistricting] plan will be constitutionally suspect if the largest and smallest districts [within a state or jurisdiction] are more than 10 percent apart."[14]

    State-based requirements

    In addition to the federal criteria noted above, individual states may impose additional requirements on redistricting. Common state-level redistricting criteria are listed below.

    1. Contiguity refers to the principle that all areas within a district should be physically adjacent. A total of 49 states require that districts of at least one state legislative chamber be contiguous (Nevada has no such requirement, imposing no requirements on redistricting beyond those enforced at the federal level). A total of 23 states require that congressional districts meet contiguity requirements.[14][15]
    2. Compactness refers to the general principle that the constituents within a district should live as near to one another as practicable. A total of 37 states impose compactness requirements on state legislative districts; 18 states impose similar requirements for congressional districts.[14][15]
    3. A community of interest is defined by FairVote as a "group of people in a geographical area, such as a specific region or neighborhood, who have common political, social or economic interests." A total of 24 states require that the maintenance of communities of interest be considered in the drawing of state legislative districts. A total of 13 states impose similar requirements for congressional districts.[14][15]
    4. A total of 42 states require that state legislative district lines be drawn to account for political boundaries (e.g., the limits of counties, cities, and towns). A total of 19 states require that similar considerations be made in the drawing of congressional districts.[14][15]

    Methods

    In general, a state's redistricting authority can be classified as one of the following:[16]

    1. Legislature-dominant: In a legislature-dominant state, the legislature retains the ultimate authority to draft and enact district maps. Maps enacted by the legislature may or may not be subject to gubernatorial veto. Advisory commissions may also be involved in the redistricting process, although the legislature is not bound to adopt an advisory commission's recommendations.
    2. Commission: In a commission state, an extra-legislative commission retains the ultimate authority to draft and enact district maps. A non-politician commission is one whose members cannot hold elective office. A politician commission is one whose members can hold elective office.
    3. Hybrid: In a hybrid state, the legislature shares redistricting authority with a commission.

    Gerrymandering

    In 1812, Massachusetts Governor Elbridge Gerry signed into law a state Senate district map that, according to the Encyclopædia Britannica, "consolidated the Federalist Party vote in a few districts and thus gave disproportionate representation to Democratic-Republicans." The word gerrymander was coined by The Boston Gazette to describe the district.
    See also: Gerrymandering

    The term gerrymandering refers to the practice of drawing electoral district lines to favor one political party, individual, or constituency over another. When used in a rhetorical manner by opponents of a particular district map, the term has a negative connotation but does not necessarily address the legality of a challenged map. The term can also be used in legal documents; in this context, the term describes redistricting practices that violate federal or state laws.[1][17]

    For additional background information about gerrymandering, click "[Show more]" below.

    Show more

    The phrase racial gerrymandering refers to the practice of drawing electoral district lines to dilute the voting power of racial minority groups. Federal law prohibits racial gerrymandering and establishes that, to combat this practice and to ensure compliance with the Voting Rights Act, states and jurisdictions can create majority-minority electoral districts. A majority-minority district is one in which a racial group or groups comprise a majority of the district's populations. Racial gerrymandering and majority-minority districts are discussed in greater detail in this article.[18]

    The phrase partisan gerrymandering refers to the practice of drawing electoral district maps with the intention of favoring one political party over another. In contrast with racial gerrymandering, on which the Supreme Court of the United States has issued rulings in the past affirming that such practices violate federal law, the high court had not, as of November 2017, issued a ruling establishing clear precedent on the question of partisan gerrymandering. Although the court has granted in past cases that partisan gerrymandering can violate the United States Constitution, it has never adopted a standard for identifying or measuring partisan gerrymanders. Partisan gerrymandering is described in greater detail in this article.[19][20]

    Recent court decisions

    See also: Redistricting cases heard by the Supreme Court of the United States

    The Supreme Court of the United States has, in recent years, issued several decisions dealing with redistricting policy, including rulings relating to the consideration of race in drawing district maps, the use of total population tallies in apportionment, and the constitutionality of independent redistricting commissions. The rulings in these cases, which originated in a variety of states, impact redistricting processes across the nation.

    For additional background information about these cases, click "[Show more]" below.

    Show more

    Alexander v. South Carolina State Conference of the NAACP (2024)

    See also: Alexander v. South Carolina State Conference of the NAACP

    Alexander v. South Carolina State Conference of the NAACP — This case concerns a challenge to the congressional redistricting plan that the South Carolina legislature enacted after the 2020 census. In January 2023, a federal three-judge panel ruled that the state's 1st Congressional District was unconstitutional and enjoined the state from conducting future elections using its district boundaries. The panel's opinion said, "The Court finds that race was the predominant factor motivating the General Assembly’s adoption of Congressional District No. 1...Defendants have made no showing that they had a compelling state interest in the use of race in the design of Congressional District No. 1 and thus cannot survive a strict scrutiny review."[21] Thomas Alexander (R)—in his capacity as South Carolina State Senate president—appealed the federal court's ruling, arguing: :In striking down an isolated portion of South Carolina Congressional District 1 as a racial gerrymander, the panel never even mentioned the presumption of the General Assembly’s “good faith.”...The result is a thinly reasoned order that presumes bad faith, erroneously equates the purported racial effect of a single line in Charleston County with racial predominance across District 1, and is riddled with “legal mistake[s]” that improperly relieved Plaintiffs of their “demanding” burden to prove that race was the “predominant consideration” in District 1.[22] The U.S. Supreme Court scheduled oral argument on this case for October 11, 2023.[23]

    Moore v. Harper (2023)

    See also: Moore v. Harper

    At issue in Moore v. Harper, was whether state legislatures alone are empowered by the Constitution to regulate federal elections without oversight from state courts, which is known as the independent state legislature doctrine. On November 4, 2021, the North Carolina General Assembly adopted a new congressional voting map based on 2020 Census data. The legislature, at that time, was controlled by the Republican Party. In the case Harper v. Hall (2022), a group of Democratic Party-affiliated voters and nonprofit organizations challenged the map in state court, alleging that the new map was a partisan gerrymander that violated the state constitution.[24] On February 14, 2022, the North Carolina Supreme Court ruled that the state could not use the map in the 2022 elections and remanded the case to the trial court for further proceedings. The trial court adopted a new congressional map drawn by three court-appointed experts. The United States Supreme Court affirmed the North Carolina Supreme Court's original decision in Moore v. Harper that the state's congressional district map violated state law. In a 6-3 decision, Chief Justice John Roberts wrote that the "Elections Clause does not vest exclusive and independent authority in state legislatures to set the rules regarding federal elections.[25]

    Merrill v. Milligan (2023)

    See also: Merrill v. Milligan

    At issue in Merrill v. Milligan, was the constitutionality of Alabama's 2021 redistricting plan and whether it violated Section 2 of the Voting Rights Act. A group of Alabama voters and organizations sued Secretary of State John Merrill (R) and the House and Senate redistricting chairmen, Rep. Chris Pringle (R) and Sen. Jim McClendon (R). Plaintiffs alleged the congressional map enacted on Nov. 4, 2021, by Gov. Kay Ivey (R) unfairly distributed Black voters. The plaintiffs asked the lower court to invalidate the enacted congressional map and order a new map with instructions to include a second majority-Black district. The court ruled 5-4, affirming the lower court opinion that the plaintiffs showed a reasonable likelihood of success concerning their claim that Alabama's redistricting map violated Section 2 of the Voting Rights Act.[26]

    Gill v. Whitford (2018)

    See also: Gill v. Whitford

    In Gill v. Whitford, decided on June 18, 2018, the Supreme Court of the United States ruled that the plaintiffs—12 Wisconsin Democrats who alleged that Wisconsin's state legislative district plan had been subject to an unconstitutional gerrymander in violation of the First and Fourteenth Amendments—had failed to demonstrate standing under Article III of the United States Constitution to bring a complaint. The court's opinion, penned by Chief Justice John Roberts, did not address the broader question of whether partisan gerrymandering claims are justiciable and remanded the case to the district court for further proceedings. Roberts was joined in the majority opinion by Associate Justices Anthony Kennedy, Ruth Bader Ginsburg, Stephen Breyer, Samuel Alito, Sonia Sotomayor, and Elena Kagan. Kagan penned a concurring opinion joined by Ginsburg, Breyer, and Sotomayor. Associate Justice Clarence Thomas penned an opinion that concurred in part with the majority opinion and in the judgment, joined by Associate Justice Neil Gorsuch.[27]

    Cooper v. Harris (2017)

    See also: Cooper v. Harris

    In Cooper v. Harris, decided on May 22, 2017, the Supreme Court of the United States affirmed the judgment of the United States District Court for the Middle District of North Carolina, finding that two of North Carolina's congressional districts, the boundaries of which had been set following the 2010 United States Census, had been subject to an illegal racial gerrymander in violation of Section 2 of the Voting Rights Act. Justice Elena Kagan delivered the court's majority opinion, which was joined by Justices Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer, and Sonia Sotomayor (Thomas also filed a separate concurring opinion). In the court's majority opinion, Kagan described the two-part analysis utilized by the high court when plaintiffs allege racial gerrymandering as follows: "First, the plaintiff must prove that 'race was the predominant factor motivating the legislature's decision to place a significant number of voters within or without a particular district.' ... Second, if racial considerations predominated over others, the design of the district must withstand strict scrutiny. The burden shifts to the State to prove that its race-based sorting of voters serves a 'compelling interest' and is 'narrowly tailored' to that end." In regard to the first part of the aforementioned analysis, Kagan went on to note that "a plaintiff succeeds at this stage even if the evidence reveals that a legislature elevated race to the predominant criterion in order to advance other goals, including political ones." Justice Samuel Alito delivered an opinion that concurred in part and dissented in part with the majority opinion. This opinion was joined by Chief Justice John Roberts and Justice Anthony Kennedy.[28][29][30]

    Evenwel v. Abbott (2016)

    See also: Evenwel v. Abbott

    Evenwel v. Abbott was a case decided by the Supreme Court of the United States in 2016. At issue was the constitutionality of state legislative districts in Texas. The plaintiffs, Sue Evenwel and Edward Pfenninger, argued that district populations ought to take into account only the number of registered or eligible voters residing within those districts as opposed to total population counts, which are generally used for redistricting purposes. Total population tallies include non-voting residents, such as immigrants residing in the country without legal permission, prisoners, and children. The plaintiffs alleged that this tabulation method dilutes the voting power of citizens residing in districts that are home to smaller concentrations of non-voting residents. The court ruled 8-0 on April 4, 2016, that a state or locality can use total population counts for redistricting purposes. The majority opinion was penned by Justice Ruth Bader Ginsburg.[31][32][33][34]

    Harris v. Arizona Independent Redistricting Commission (2016)

    Justice Stephen Breyer penned the majority opinion in Harris v. Arizona Independent Redistricting Commission.
    See also: Harris v. Arizona Independent Redistricting Commission

    Harris v. Arizona Independent Redistricting Commission was a case decided by the Supreme Court of the United States in 2016. At issue was the constitutionality of state legislative districts that were created by the commission in 2012. The plaintiffs, a group of Republican voters, alleged that "the commission diluted or inflated the votes of almost two million Arizona citizens when the commission intentionally and systematically overpopulated 16 Republican districts while under-populating 11 Democrat districts." This, the plaintiffs argued, constituted a partisan gerrymander. The plaintiffs claimed that the commission placed a disproportionately large number of non-minority voters in districts dominated by Republicans; meanwhile, the commission allegedly placed many minority voters in smaller districts that tended to vote Democratic. As a result, the plaintiffs argued, more voters overall were placed in districts favoring Republicans than in those favoring Democrats, thereby diluting the votes of citizens in the Republican-dominated districts. The defendants countered that the population deviations resulted from legally defensible efforts to comply with the Voting Rights Act and obtain approval from the United States Department of Justice. At the time of redistricting, certain states were required to obtain preclearance from the U.S. Department of Justice before adopting redistricting plans or making other changes to their election laws—a requirement struck down by the United States Supreme Court in Shelby County v. Holder (2013). On April 20, 2016, the court ruled unanimously that the plaintiffs had failed to prove that a partisan gerrymander had taken place. Instead, the court found that the commission had acted in good faith to comply with the Voting Rights Act. The court's majority opinion was penned by Justice Stephen Breyer.[35][36][37]

    Arizona State Legislature v. Arizona Independent Redistricting Commission (2015)

    See also: Arizona State Legislature v. Arizona Independent Redistricting Commission
    Arizona State Legislature v. Arizona Independent Redistricting Commission was a case decided by the Supreme Court of the United States in 2015. At issue was the constitutionality of the Arizona Independent Redistricting Commission, which was established by state constitutional amendment in 2000. According to Article I, Section 4 of the United States Constitution, "the Times, Places and Manner of holding Elections for Senators and Representatives shall be prescribed in each State by the Legislature thereof." The state legislature argued that the use of the word "legislature" in this context is literal; therefore, only a state legislature may draw congressional district lines. Meanwhile, the commission contended that the word "legislature" ought to be interpreted to mean "the legislative powers of the state," including voter initiatives and referenda. On June 29, 2015, the court ruled 5-4 in favor of the Arizona Independent Redistricting Commission, finding that "redistricting is a legislative function, to be performed in accordance with the state's prescriptions for lawmaking, which may include the referendum and the governor's veto." The majority opinion was penned by Justice Ruth Bader Ginsburg and joined by Justices Anthony Kennedy, Stephen Breyer, Elena Kagan, and Sonia Sotomayor. Chief Justice John Roberts and Justices Clarence Thomas, Antonin Scalia, and Samuel Alito dissented.[38][39][40][41]

    Race and ethnicity

    See also: Majority-minority districts

    Section 2 of the Voting Rights Act of 1965 mandates that electoral district lines cannot be drawn in such a manner as to "improperly dilute minorities' voting power."

    No voting qualification or prerequisite to voting, or standard, practice, or procedure shall be imposed or applied by any State or political subdivision to deny or abridge the right of any citizen of the United States to vote on account of race or color.[11]
    —Voting Rights Act of 1965[42]

    States and other political subdivisions may create majority-minority districts in order to comply with Section 2 of the Voting Rights Act. A majority-minority district is a district in which minority groups compose a majority of the district's total population. As of 2015, Ohio was home to one congressional majority-minority district.[2][3][4]

    Proponents of majority-minority districts maintain that these districts are a necessary hindrance to the practice of cracking, which occurs when a constituency is divided between several districts in order to prevent it from achieving a majority in any one district. In addition, supporters argue that the drawing of majority-minority districts has resulted in an increased number of minority representatives in state legislatures and Congress.[2][3][4]

    Critics, meanwhile, contend that the establishment of majority-minority districts can result in packing, which occurs when a constituency or voting group is placed within a single district, thereby minimizing its influence in other districts. Because minority groups tend to vote Democratic, critics argue that majority-minority districts ultimately present an unfair advantage to Republicans by consolidating Democratic votes into a smaller number of districts.[2][3][4]


    State process

    See also: State-by-state redistricting procedures

    Congressional redistricting procedures in Ohio

    On May 8, 2018, voters in Ohio approved a constitutional amendment establishing new procedures for congressional redistricting. Beginning with the 2020 redistricting cycle, the following provisions were set to take effect:[43][44]

    • Following completion of the United States Census, state legislators can adopt a new congressional district map if three-fifths of the legislature's total membership vote to approve, including one-half of the minority party members. This map would apply for 10 years.
    • If the legislature proves unable to adopt a new map, a commission will be formed to adopt a map. That commission will include the governor, state auditor, secretary of state, and four legislators, two of whom must come from the legislature's minority party. A majority of the commission's members, including two members belonging to the minority party, must agree on a map. The map would apply for 10 years.
    • If the commission proves unable to adopt a map, state legislators will be given a second chance to adopt a map. The map would have to be approved by three-fifths of the legislature's total membership, including one-third of the minority party's members. The map would apply for 10 years.
    • If the legislature fails a second time, the majority party of the legislature, without support from the minority party, can adopt a map that would apply for four years.

    Maps drawn by the legislature can be vetoed by the governor or a veto referendum campaign. The amendment stipulates that 65 of Ohio's counties cannot be split during redistricting (18 can be split once, and the state's five most populous counties can be split twice).[43][44]

    State legislative redistricting procedures in Ohio

    On November 3, 2015, voters in Ohio approved a constitutional amendment to create a bipartisan state legislative redistricting commission. The commission comprises seven members: the governor, state auditor, secretary of state, one person appointed by the speaker of the Ohio House of Representatives, one person appointed by the House leader of the largest political party of which the speaker is not a member, one person appointed by the President of the Ohio State Senate, and one person appointed by the Senate leader of the largest political party of which the president is not a member.[45][46]

    Maps drawn by the commission are valid for 10 years if at least two commissioners from each major political party vote for them. Should the maps be passed along strictly partisan lines, the maps are valid for four years.[45][46]

    A six-member advisory commission is also involved in the congressional and state legislative redistricting processes. The majority leaders of the Ohio House of Representatives and the Ohio State Senate each appoint three members, "at least one of whom must be from a different party, and at least one of whom must not be a legislator."[47]

    All legislative districts are required to be compact and made of "contiguous territory." Also, the "boundary of each district [must] be a single nonintersecting continuous line." The amendment forbids district plans from favoring or disfavoring either political party.[45][46]

    How incarcerated persons are counted for redistricting

    See also: How incarcerated persons are counted for redistricting

    States differ on how they count incarcerated persons for the purposes of redistricting. In Ohio, incarcerated persons are counted in the correctional facilities they are housed in.

    District maps

    Congressional districts

    See also: United States congressional delegations from Ohio

    Ohio comprises 15 congressional districts. The table below lists Ohio's current U.S. Representatives.


    Office Name Party Date assumed office Date term ends
    U.S. House Ohio District 1 Greg Landsman Democratic January 3, 2023 January 3, 2025
    U.S. House Ohio District 2 Brad Wenstrup Republican January 3, 2013 January 3, 2025
    U.S. House Ohio District 3 Joyce Beatty Democratic January 3, 2013 January 3, 2025
    U.S. House Ohio District 4 Jim Jordan Republican January 3, 2007 January 3, 2025
    U.S. House Ohio District 5 Bob Latta Republican January 3, 2007 January 3, 2025
    U.S. House Ohio District 6 Michael Rulli Republican June 25, 2024 January 3, 2025
    U.S. House Ohio District 7 Max Miller Republican January 3, 2023 January 3, 2025
    U.S. House Ohio District 8 Warren Davidson Republican June 9, 2016 January 3, 2025
    U.S. House Ohio District 9 Marcy Kaptur Democratic January 3, 1983 January 3, 2025
    U.S. House Ohio District 10 Michael Turner Republican January 3, 2013 January 3, 2025
    U.S. House Ohio District 11 Shontel Brown Democratic November 4, 2021 January 3, 2025
    U.S. House Ohio District 12 Troy Balderson Republican September 5, 2018 January 3, 2025
    U.S. House Ohio District 13 Emilia Sykes Democratic January 3, 2023 January 3, 2025
    U.S. House Ohio District 14 David Joyce Republican January 3, 2013 January 3, 2025
    U.S. House Ohio District 15 Mike Carey Republican November 4, 2021 January 3, 2025


    State legislative maps

    See also: Ohio State Senate and Ohio House of Representatives

    Ohio comprises 33 state Senate districts and 99 state House districts. Each Senate district comprises three House districts. State senators are elected every four years in partisan elections. State representatives are elected every two years in partisan elections. To access the state legislative district maps approved during the 2020 redistricting cycle, click here.

    Redistricting by cycle

    Redistricting after the 2020 census

    See also: Redistricting in Ohio after the 2020 census

    Ohio was apportioned 15 seats in the U.S. House of Representatives. This represented a net loss of one seat as compared to apportionment after the 2010 census.[48] This section lists major events in the post-2020 census redistricting cycle in reverse chronological order. Major events include the release of apportionment data, the release of census population data, the introduction of formal map proposals, the enactment of new maps, and noteworthy court challenges. Click the dates below for additional information.

    • November 27, 2023: The Ohio Supreme Court upheld the state's legislative maps, dismissing several lawsuits against them.[8][49]
    • September 7, 2023: The Ohio Supreme Court dismissed Huffman v. Neiman after the petitioners who filed the original lawsuit requested the court to dismiss the case and leave the boundaries in place for the 2024 election.[50][51]
    • June 30, 2023: The U.S. Supreme Court vacated the Ohio Supreme Court's decision that ruled the congressional district boundaries that the Ohio Redistricting Commission adopted on March 2, 2022, were unconstitutional. SCOTUS remanded the case back to the state supreme court for consideration in light of SCOTUS' decision in Moore v. Harper.[52]
    • July 19, 2022: The Ohio Supreme Court ruled in a 4-3 decision that the congressional district boundaries that the Ohio Redistricting Commission adopted on March 2, 2022, were unconstitutional. The 2022 congressional elections will take place using the boundaries the redistricting commission adopted in March 2022 and the state supreme court directed the Ohio General Assembly to pass a compliant plan within 30 days.
    • May 28, 2022: A federal court ruling took effect, which ordered the use of legislative maps approved by the Ohio Redistricting Commission in February for the 2022 elections.
    • May 25, 2022: The Ohio Supreme Court rejected the Ohio Redistricting Commission's resubmitted legislative maps and ordered the commission to redraw them.
    • May 5, 2022: The Ohio Redistricting Commission voted to resubmit maps it had approved on February 24 to the Ohio Supreme Court.
    • April 20, 2022: A federal court ruled that if legislative maps were not approved by the state court by May 28, the federal court would order an August 2 primary election date using the third set of maps approved by the Ohio Redistricting Commission.
    • April 14, 2022: The Ohio Supreme Court rejected the Ohio Redistricting Commission's redrawn legislative maps and ordered the commission to redraw them.
    • March 28, 2022: The Ohio Redistricting Commission voted to approve redrawn legislative maps.
    • March 21, 2022: A lawsuit was filed challenging the March 2 congressional map (Neiman v. LaRose).
    • March 18, 2022: The Ohio Supreme Court ruled that it did not have jurisdiction to overturn the redrawn congressional map approved by the redistricting commission on March 2.
    • March 7, 2022: The Ohio Supreme Court rejected the Ohio Redistricting Commission's redrawn legislative maps and ordered the commission to redraw them.
    • March 2, 2022: The Ohio Redistricting Commission voted 5-2 to approve a redrawn congressional map.
    • February 24, 2022: The Ohio Redistricting Commission voted 4-3 to approve redrawn legislative maps.
    • February 18, 2022: A federal lawsuit was filed against the Ohio Redistricting Commission. The lawsuit asked the district court to enact the second set of legislative maps that had previously been struck down by the Ohio Supreme Court (Gonidakis v. Ohio Redistricting Commission).
    • February 17, 2022: The Ohio Redistricting Commission did not meet the court-ordered deadline to draw new legislative maps.
    • February 9, 2022: Ohio legislative leaders said they would not draw a new congressional map, meaning the Ohio Redistricting Commission assumed responsibility for drawing the map.
    • February 7, 2022: The Ohio Supreme Court struck down the Ohio Redistricting Commission's second set of approved legislative maps and ordered the commission to redraw them within 10 days.
    • January 25, 2022: The plaintiffs in three cases challenging the state legislative maps filed objections against the revised legislative maps (Ohio Organizing Collaborative v. Ohio Redistricting Commission, Bennett v. Ohio Redistricting Commission, and League of Women Voters of Ohio v. Ohio Redistricting Commission).
    • January 22, 2022: The Ohio Redistricting Commission voted 5-2 to approve a new set of state legislative maps.
    • January 14, 2022: The Ohio Supreme Court ruled against the state's enacted congressional map and ordered the Ohio State Legislature to redraw it.
    • January 12, 2022: The Ohio Supreme Court ruled against the state's enacted legislative maps and ordered the Ohio Redistricting Commission to redraw them within 10 days.
    • November 30, 2021:
    • November 22, 2021: A lawsuit was filed in the Ohio Supreme Court challenging Ohio's enacted congressional map (Adams v. DeWine).
    • November 20, 2021: Governor Mike DeWine (R) signed the congressional map into law.
    • November 18, 2021: The Ohio House of Representatives approved the congressional map in a 55-36 vote.
    • November 16, 2021: The Ohio State Senate voted 24-7 to approve the congressional map.
    • November 15, 2021: Members of the Ohio State Legislature released their final congressional map proposal.
    • October 31, 2021: The Ohio Redistricting Commission did not enact maps before the second deadline for congressional map enactment.
    • September 30, 2021: The state legislature did not enact maps before the first deadline for congressional map enactment.
    • September 27, 2021: A third lawsuit was filed in the Ohio Supreme Court challenging Ohio's enacted legislative maps (Ohio Organizing Collaborative v. Ohio Redistricting Commission).
    • September 24, 2021: A second lawsuit was filed in the Ohio Supreme Court challenging Ohio's enacted legislative maps (Bennett v. Ohio Redistricting Commission).
    • September 23, 2021: A lawsuit was filed in the Ohio Supreme Court challenging Ohio's enacted legislative maps (League of Women Voters of Ohio v. Ohio Redistricting Commission).
    • September 16, 2021: The U.S. Census Bureau released data from the 2020 census in an easier-to-use format to state redistricting authorities and the public.
    • September 15, 2021: The Ohio Redistricting Commission approved state legislative maps for four years in a 5-2 commission vote.
    • September 9, 2021: Members of the Ohio Redistricting Commission released legislative redistricting proposals.
    • August 31, 2021: Members of the Ohio Redistricting Commission released legislative redistricting proposals.
    • August 12, 2021: The U.S. Census Bureau delivered redistricting data to states in a legacy format.
    • April 26, 2021: The U.S. Census Bureau delivered apportionment counts.

    Enacted state legislative district maps

    State legislative maps enacted in 2023

    See also: State legislative district maps implemented after the 2020 census

    On September 23, 2023, the Ohio state legislature adopted new legislative maps.[53] These maps were upheld by the Ohio Supreme Court on November 27, 2023.[8]

    State Senate

    Below is the state Senate map in effect before and after the 2020 redistricting cycle. The map on the right was in effect for Ohio’s 2024 state legislative elections.

    Ohio State Senate Districts
    until December 31, 2022

    Click a district to compare boundaries.

    Ohio State Senate Districts
    starting January 1, 2023

    Click a district to compare boundaries.


    State House of Representatives

    Below is the state House map in effect before and after the 2020 redistricting cycle. The map on the right was in effect for Ohio’s 2024 state legislative elections.

    Ohio State House Districts
    until December 31, 2022

    Click a district to compare boundaries.

    Ohio State House Districts
    starting January 1, 2023

    Click a district to compare boundaries.


    State legislative maps enacted in 2021-2022

    A federal court ruling on Ohio's legislative maps took effect on May 28, 2022, which ordered maps drawn by the Ohio Redistricting Commission in February be used for the 2022 elections and set a legislative primary date of August 2.[54] These maps took effect for Ohio's 2022 state legislative elections.

    The Ohio Redistricting Commission approved new state legislative district maps by a 5-2 vote on September 16, 2021. The two Democratic members of the commission, state Rep. Emilia Sykes (D) and state Sen. Vernon Sykes (D), dissented.[55] Senate President Matt Huffman (R), a member of the commission, estimated that the new maps would create 62 Republican seats and 37 Democratic seats in the House, and 23 Republican seats and 10 Democratic seats in the Senate. Cleveland.com reported that Democrats on the commission agreed with Huffman's Senate estimates, but said the new House map would create 65 Republican seats and 34 Democratic seats.[55]

    On January 12, 2022, the Ohio Supreme Court ruled against the state's enacted legislative maps, ordering the Ohio Redistricting Commission to redraw them within 10 days.[56] The commission voted to approve a new set of maps in a 5-2 vote on January 22. Click here to view the House map, and click here to view the Senate map.

    On February 7, 2022, the Ohio Supreme Court rejected the state's redrawn legislative maps and ordered the Ohio Redistricting Commission to submit new maps.[57][58] The commission did not meet the February 17 deadline.[59] On February 24, the Ohio Redistricting Commission voted 4-3 to approve new legislative maps. The maps can be viewed here. State Auditor Keith Faber (R) joined the two Democratic members of the commission in voting against the maps.[60]

    On March 7, the Ohio Supreme Court rejected redrawn legislative maps and ordered the Ohio Redistricting Commission to draw new maps by March 28.[61] On March 22, the commission agreed to appoint two independent consultants to assist in the map-making process.[62] State Sen. Vernon Sykes (D) nominated University of Florida political science professor Michael McDonald and state Rep. Bob Cupp (R) nominated National Demographics Corporation president Douglas Johnson.[63] On March 28, the Ohio Redistricting Commission approved new state legislative district boundaries in a 4-3 vote. DeWine, La Rose, Huffman, and Cupp voted to approve the new boundaries, and Russo, Sykes, and Faber voted against.[64] The commission approved maps it had drawn, since the Senate map drawn by the independent consultants was not complete at the time of the vote.[65] Click here to view the maps.

    On April 14, the Ohio Supreme Court rejected the Ohio Redistricting Commission's legislative maps for the fourth time and ordered the commission to redraw the maps by May 6.[66] On May 5, the commission voted 4-3 to resubmit legislative maps it had previously submitted to the court on February 24.[67] DeWine, La Rose, Huffman, and Cupp voted to approve the boundaries, and Russo, Sykes, and Faber voted against.[67] The Ohio Supreme Court struck down the maps on May 25 and ordered the commission to redraw them by June 3.[68]

    The maps can be viewed here.


    Reactions to 2021-2022 state legislative maps

    A statement from the commission explaining the manner by which districts were allocated said: "The Commission considered statewide state and federal partisan general election results during the last ten years. There were sixteen such contests. When considering the results of each of those elections, the Commission determined that Republican candidates won thirteen out of sixteen of those elections. [...] Accordingly, the statewide proportion of districts whose voters favor each political party corresponds closely to the statewide preferences of the voters of Ohio."[69]

    Following the enactment of the maps, Huffman released a statement saying: “These house and senate maps will be in place for the next four years, and represent an important first step towards approving the next map that will complete the decade. [...] I’m convinced we could’ve reached a ten-year map. However, special interests pressured democrats to not support it, asking voters to extend the deadline to accomplish that.”[70]

    Leading up to the vote, Emilia Sykes disapproved of the maps saying they were overly partisan and she would “call it offensive and plain wrong to move forward this map [...] to put forth something that so arrogantly flies in the face of what people, our voters, asked us to do, not once, but twice.”[55]

    Commission members Gov. Mike DeWine (R) and Secretary of State Frank LaRose (R) expressed disapproval of the maps and said they expected court challenges to follow their vote. DeWine said: “Along with the secretary of state I will vote to send this matter forward but it will not be the end of it. We know that this matter will be in court. [...] What I am sure in my heart is that this committee could have come up with a bill that was much more clearly constitutional.”[71]

    Redistricting after the 2010 census

    See also: Redistricting in Ohio after the 2010 census

    Congressional redistricting, 2010

    Following the 2010 United States Census, Ohio lost two congressional seats. At the time of redistricting, Republicans held the governorship and both chambers of the Ohio General Assembly. On September 21, 2011, the legislature approved a congressional map, which was signed into law on September 26, 2011. Opponents threatened to subject the map to a veto referendum. In Ohio, legislation that is not related to spending may be subjected to a veto referendum if it does not pass the legislature by a two-thirds vote. Democratic opponents of the maps commenced a petition drive to put the issue before voters in the next statewide election. This proved unnecessary, however, as a revised congressional map passed the state legislature on December 14, 2011, and was signed into law the next day.[47][72]

    A constitutional amendment that would have established an independent congressional redistricting commission was defeated by voters on November 6, 2012.

    On May 3, 2019, a three-judge panel of the United States District Court for the Southern District of Ohio ruled unanimously that Ohio's congressional district plan constituted an illegal partisan gerrymander. The court held that the plan, enacted in 2011 by a Republican legislature and governor, violated the First and Fourteenth Amendment rights of Democrats. The panel, comprising Judges Karen Moore (appointed by Democrat Bill Clinton), Timothy Black (appointed by Democrat Barack Obama), and Michael Watson (appointed by Republican George W. Bush), enjoined the state from conducting any future congressional elections under the 2011 plan. The court ordered the state to enact a remedial plan by June 14, 2019. On May 10, 2019, state officials petitioned the Supreme Court of the United States for a stay of the lower court's ruling.[73][74] The high court granted the stay on May 24, 2019.[75]

    State legislative redistricting, 2010

    On September 28, 2011, the politician redistricting commission approved new state legislative district maps. Although these maps were subject to litigation, they were ultimately upheld.[47]

    State legislation and ballot measures

    Redistricting legislation

    DocumentIcon.jpg See state election laws

    The following is a list of recent redistricting bills that have been introduced in or passed by the Ohio state legislature. To learn more about each of these bills, click the bill title. This information is provided by BillTrack50.

    Note: Due to the nature of the sorting process used to generate this list, some results may not be relevant to the topic. If no bills are displayed below, no legislation pertaining to this topic has been introduced in the legislature recently.

    Redistricting ballot measures

    See also: Redistricting measures on the ballot and List of Ohio ballot measures

    Ballotpedia has tracked the following ballot measure(s) relating to redistricting in Ohio.

    1. Ohio Apportionment of Legislative Districts Amendment (May 1967)
    2. Ohio Legislative Redistricting Amendment (May 1965)
    3. Ohio Congressional District Apportionment Referendum (1915)
    4. Ohio Issue No. 4, Redistricting Commission Initiative (2005)
    5. Ohio Senatorial Reapportionment Amendment (1921)
    6. Ohio Issue 2, Congressional and Legislative Redistricting Commission Amendment (2012)
    7. Ohio County Representation, Amendment 2 (1903)
    8. Ohio Redistricting of Legislative Districts Amendment (1967)
    9. Ohio Establishment of Reapportionment and Redistricting Commission Initiative (1981)
    10. Ohio Bipartisan Redistricting Commission Amendment, Issue 1 (2015)
    11. Ohio Legislative Districts, Amendment 5 (October 1857)
    12. Ohio Apportionment of the General Assembly, Amendment 1 (1889)
    13. Ohio Apportionment of the General Assembly, Amendment 1 (1893)
    14. Ohio Citizens Redistricting Commission Amendment (2024)

    Political impacts of redistricting

    Competitiveness

    There are conflicting opinions regarding the correlation between partisan gerrymandering and electoral competitiveness. In 2012, Jennifer Clark, a political science professor at the University of Houston, said, "The redistricting process has important consequences for voters. In some states, incumbent legislators work together to protect their own seats, which produces less competition in the political system. Voters may feel as though they do not have a meaningful alternative to the incumbent legislator. Legislators who lack competition in their districts have less incentive to adhere to their constituents’ opinions."[76]

    In 2006, Emory University professor Alan Abramowitz and Ph.D. students Brad Alexander and Matthew Gunning wrote, "[Some] studies have concluded that redistricting has a neutral or positive effect on competition. ... [It] is often the case that partisan redistricting has the effect of reducing the safety of incumbents, thereby making elections more competitive."[77]

    In 2011, James Cottrill, a professor of political science at Santa Clara University, published a study of the effect of non-legislative approaches (e.g., independent commissions, politician commissions) to redistricting on the competitiveness of congressional elections. Cottrill found that "particular types of [non-legislative approaches] encourage the appearance in congressional elections of experienced and well-financed challengers." Cottrill cautioned, however, that non-legislative approaches "contribute neither to decreased vote percentages when incumbents win elections nor to a greater probability of their defeat."[78]

    In 2021, John Johnson, Research Fellow in the Lubar Center for Public Policy Research and Civic Education at Marquette University, reviewed the relationship between partisan gerrymandering and political geography in Wisconsin, a state where Republicans have controlled both chambers of the state legislature since 2010 while voting for the Democratic nominee in every presidential election but one since 1988. After analyzing state election results since 2000, Johnson wrote, "In 2000, 42% of Democrats and 36% of Republicans lived in a neighborhood that the other party won. Twenty years later, 43% of Democrats lived in a place Trump won, but just 28% of Republicans lived in a Biden-voting neighborhood. Today, Democrats are more likely than Republicans to live in both places where they are the overwhelming majority and places where they form a noncompetitive minority."[79]

    State legislatures after the 2010 redistricting cycle

    See also: Margin of victory in state legislative elections

    In 2014, Ballotpedia conducted a study of competitive districts in 44 state legislative chambers between 2010, the last year in which district maps drawn after the 2000 census applied, and 2012, the first year in which district maps drawn after the 2010 census applied. Ballotpedia found that there were 61 fewer competitive general election contests in 2012 than in 2010. Of the 44 chambers studied, 25 experienced a net loss in the number of competitive elections. A total of 17 experienced a net increase. In total, 16.2 percent of the 3,842 legislative contests studied saw competitive general elections in 2010. In 2012, 14.6 percent of the contests studied saw competitive general elections. An election was considered competitive if it was won by a margin of victory of 5 percent or less. An election was considered mildly competitive if it was won by a margin of victory between 5 and 10 percent. For more information regarding this report, including methodology, see this article.

    In Ohio, there were seven competitive races for the Ohio House of Representatives in 2012, compared to fourteen in 2010. There were ten mildly competitive House races in 2012, compared to nine in 2010. This amounted to a net loss of six competitive elections.

    Recent news

    The link below is to the most recent stories in a Google news search for the terms Redistricting Ohio. These results are automatically generated from Google. Ballotpedia does not curate or endorse these articles.

    See also

    External links

    Footnotes

    1. 1.0 1.1 All About Redistricting, "Why does it matter?" accessed April 8, 2015
    2. 2.0 2.1 2.2 2.3 Indy Week, "Cracked, stacked and packed: Initial redistricting maps met with skepticism and dismay," June 29, 2011
    3. 3.0 3.1 3.2 3.3 The Atlantic, "How the Voting Rights Act Hurts Democrats and Minorities," June 17, 2013
    4. 4.0 4.1 4.2 4.3 Redrawing the Lines, "The Role of Section 2 - Majority Minority Districts," accessed April 6, 2015
    5. Dayton Daily News, "Ohio Redistricting Commission approves new U.S. House map on another party-line vote," March 2, 2022
    6. 13ABC, "Ohio Supreme Court makes final judgement on Congressional map challenges," March 18, 2022
    7. Ohio Redistricting Commission, "General Assembly District Plan - Adopted by Commission," accessed December 21, 2023
    8. 8.0 8.1 8.2 AP, "Ohio Supreme Court dismisses 3 long-running redistricting lawsuits against state legislative maps," November 28, 2023
    9. The Heritage Guide to the Constitution, "Election Regulations," accessed April 13, 2015
    10. Brookings, "Redistricting and the United States Constitution," March 22, 2011
    11. 11.0 11.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    12. Brennan Center for Justice, "A Citizen's Guide to Redistricting," accessed March 25, 2015
    13. The Constitution of the United States of America, "Article 1, Section 2," accessed March 25, 2015
    14. 14.0 14.1 14.2 14.3 14.4 14.5 14.6 All About Redistricting, "Where are the lines drawn?" accessed April 9, 2015
    15. 15.0 15.1 15.2 15.3 FairVote, "Redistricting Glossary," accessed April 9, 2015
    16. All About Redistricting, "Who draws the lines?" accessed June 19, 2017
    17. Encyclopædia Britannica, "Gerrymandering," November 4, 2014
    18. Congressional Research Service, "Congressional Redistricting and the Voting Rights Act: A Legal Overview," April 13, 2015
    19. The Wall Street Journal, "Supreme Court to Consider Limits on Partisan Drawing of Election Maps," June 19, 2017
    20. The Washington Post, "Supreme Court to hear potentially landmark case on partisan gerrymandering," June 19, 2017
    21. United States District Court for the District of South Carolina, Columbia Division, "South Carolina State Conference of the NAACP, et al. v. Alexander," January 6, 2023
    22. Supreme Court of the United States, "Alexander, et al. v. The South Carolina State Conference of the NAACP, et al.," February 17, 2023
    23. SCOTUSblog, "Alexander v. South Carolina State Conference of the NAACP," accessed July 21, 2023
    24. SCOTUSblog, "Justices will hear case that tests power of state legislatures to set rules for federal elections," June 30, 2022
    25. U.S. Supreme Court, “Moore, in his Official Capacity as Speaker of The North Carolina House of Representatives, et al. v. Harper et al.," "Certiorari to the Supreme Court of North Carolina,” accessed June 16, 2023
    26. SCOTUSblog.org, "Supreme Court upholds Section 2 of Voting Rights Act," June 8, 2023
    27. Supreme Court of the United States, "Gill v. Whitford: Decision," June 18, 2018
    28. Election Law Blog, "Breaking: SCOTUS to Hear NC Racial Gerrymandering Case," accessed June 27, 2016
    29. Ballot Access News, "U.S. Supreme Court Accepts Another Racial Gerrymandering Case," accessed June 28, 2016
    30. Supreme Court of the United States, "Cooper v. Harris: Decision," May 22, 2017
    31. The Washington Post, "Supreme Court to hear challenge to Texas redistricting plan," May 26, 2015
    32. The New York Times, "Supreme Court Agrees to Settle Meaning of ‘One Person One Vote,'" May 26, 2015
    33. SCOTUSblog, "Evenwel v. Abbott," accessed May 27, 2015
    34. Associated Press, "Supreme Court to hear Texas Senate districts case," May 26, 2015
    35. SCOTUSblog, "The new look at 'one person, one vote,' made simple," July 27, 2015
    36. Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission: Brief for Appellants," accessed December 14, 2015
    37. Supreme Court of the United States, "Harris v. Arizona Independent Redistricting Commission," April 20, 2016
    38. The New York Times, "Court Skeptical of Arizona Plan for Less-Partisan Congressional Redistricting," March 2, 2015
    39. The Atlantic, "Will the Supreme Court Let Arizona Fight Gerrymandering?" September 15, 2014
    40. United States Supreme Court, "Arizona State Legislature v. Arizona Independent Redistricting Commission: Opinion of the Court," June 29, 2015
    41. The New York Times, "Supreme Court Upholds Creation of Arizona Redistricting Commission," June 29, 2015
    42. Yale Law School, The Avalon Project, "Voting Rights Act of 1965; August 6, 1965," accessed April 6, 2015
    43. 43.0 43.1 Cincinnati.com, "Everyone complains about congressional gerrymandering. Ohio just did something about it." February 6, 2018
    44. 44.0 44.1 The Ohio Legislature, "Senate Joint Resolution 5," accessed February 6, 2018
    45. 45.0 45.1 45.2 Ohio Secretary of State, "House Joint Resolution Number 12," accessed April 21, 2015
    46. 46.0 46.1 46.2 Ohio Legislative Service Commission, "HJR 12 Final Analysis ," accessed April 21, 2015
    47. 47.0 47.1 47.2 All About Redistricting, "Ohio," accessed May 8, 2015
    48. United States Census Bureau, "2020 Census Apportionment Results Delivered to the President," April 26, 2021
    49. Neiman, et al v. LaRose, et al," September 5, 2023
    50. Neiman, et al v. LaRose, et al," September 5, 2023
    51. Neiman, et al v. LaRose, et al," September 5, 2023
    52. Supreme Court of the United States, "Order List (6/30/2023)," accessed September 8, 2023
    53. Ohio Redistricting Commission, "General Assembly District Plan - Adopted by Commission," accessed December 21, 2023
    54. News 5 Cleveland, "Trump-appointed federal court judges end Ohio's redistricting battle, side with GOP," May 30, 2022
    55. 55.0 55.1 55.2 Cleveland.com, "Ohio Redistricting Commission approves new state legislative maps that maintain Republican supermajority despite anti-gerrymandering reforms," September 16, 2021
    56. Court News Ohio, "New Ohio Legislative District Maps Unconstitutional," January 12, 2022
    57. Court News Ohio, "Revised Ohio House and Senate Maps Still Unconstitutional and Must Be Re-Drawn," February 7, 2022
    58. Ohio Supreme Court, "League of Women Voters of Ohio v. Ohio Redistricting Comm.", February 7, 2022
    59. Cite error: Invalid <ref> tag; no text was provided for refs named cap217
    60. Cleveland.com, "Ohio Redistricting Commission approves state legislative map plan, again," February 25, 2022
    61. Cite error: Invalid <ref> tag; no text was provided for refs named cno3
    62. Tribune Chronicle, "Tue. 11:38 a.m.: Ohio mapmakers to meet on 4th set of statehouse districts," March 22, 2022
    63. WOSU, "Ohio Redistricting Commission will bring in two consultants to develop new Statehouse maps," March 22, 2022
    64. Cleveland.com, "Republicans on Ohio Redistricting Commission approve slightly revised version of rejected map, abandon bipartisan plan," March 28, 2022
    65. Cleveland.com, "Ohio Supreme Court again orders redistricting commission members to explain why they shouldn’t be held in contempt," March 30, 2022
    66. Cite error: Invalid <ref> tag; no text was provided for refs named legapril
    67. 67.0 67.1 Oxford Observer, "Redistricting Commission adopts maps previously rejected by Ohio Supreme Court," May 6, 2022
    68. KSTP, "Ohio’s high court rejects latest GOP-drawn Statehouse maps," May 25, 2022
    69. Statehouse News Bureau, "Republican Senate President Defends Statehouse District Maps Critics Blast As Gerrymandered And Unfair," September 16, 2021
    70. The Ohio Senate, "Redistricting Commission Approves Four Year Maps for General Assembly," September 16, 2021
    71. News5Cleveland, "Reaction pours in after Ohio Redistricting Commission votes on party lines for 4-year maps," September 16, 2021
    72. Barone, M. & McCutcheon, C. (2013). The almanac of American politics 2014 : the senators, the representatives and the governors : their records and election results, their states and districts. Chicago, IL: University of Chicago Press.
    73. United States District Court for the Southern District of Ohio, "Ohio A. Phillip Randolph Institute v. Householder: Opinion and Order," May 3, 2019
    74. Ballot Access News, "Michigan and Ohio Ask U.S. Supreme Court to Stay Orders that Require Redistricting of US House Districts," May 11, 2019
    75. Ballot Access News, "U.S. Supreme Court Grants Stay in Gerrymandering Cases in Michigan and Ohio," May 24, 2019
    76. The Daily Cougar, "Redistricting will affect November election," October 16, 2012
    77. The Journal of Politics, "Incumbency, Redistricting, and the Decline of Competition in U.S. House Elections," February 2006
    78. Polity, "The Effects of Non-Legislative Approaches to Redistricting on Competition in Congressional Elections," October 3, 2011
    79. Marquette University Law School Faculty Blog, "Why Do Republicans Overperform in the Wisconsin State Assembly? Partisan Gerrymandering Vs. Political Geography," February 11, 2021