A small question for Rick.  Why do you include Reynolds v. Sims as a
case that set murky standards?  The one person, one vote rule seems pretty
clear to me.  Indeed, as I have argued elsewhere, pluralist critics of
Reynolds were wrong to criticize Reynolds as an impediment to group-based
political competition.  Reynolds was a one-time shock that might be thought
of as moving where the ball was on the field, but it left the competition to
go on largely as before.  It was Stewart's supposedly more restrained
insistence on rationality that invited continuous judicial intervention into
districting.

     Best,

     Daniel Lowenstein
     UCLA Law School
     310-825-5148