The U.S. Constitution, therefore, requires that legislative boundaries be drawn every decade after the Census to align and realign congressional representatives with population shifts and changes. From the very beginning, however, chicanery was afoot. Revolutionary hero Patrick Henry recognized that whoever drew those legislative district lines could reward friends with political power and simultaneously banish enemies into the electoral wilderness. He therefore went after his nemesis James Madison to keep him out of Congress. Henry convinced the Virginia legislature to manipulate the
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