Despite the judicial distinction between the partisan gerrymandering that Scalia asserted was beyond the pale of the Supreme Court’s authority and racial gerrymandering that requires the highest level of judicial review, known as strict scrutiny, partisan gerrymandering is also about race. As U.S. district judges Xavier Rodriguez and Orlando Garcia observed, this seemingly colorblind method of drawing districts is, instead, all about a “party’s willingness to use race for partisan advantage.”44 The demographic composition of the parties almost dictates it. The Pew Research Center notes that in
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