Examples of Gerrymandering in History: Landmark Cases and Rulings

Examples of gerrymandering in American history stretch from an 1812 Massachusetts state senate district shaped like a salamander to twenty-first-century congressional maps drawn by computer to shave points off statewide vote shares. The most instructive cases share a pattern: an unusually shaped or unusually lopsided map, a court fight that produced a new legal standard, and a political aftermath that shaped the next round of redistricting. What follows are the episodes that matter most, in roughly the order they arrived.

The 1812 Salamander That Named the Practice

The word comes from Governor Elbridge Gerry of Massachusetts, who in February 1812 signed a redistricting bill drawn by his Democratic-Republican allies to tilt state senate elections. One Essex County district was so contorted that observers said it resembled a salamander. Boston engraver Elkanah Tisdale added a head, wings, and claws to a map of it, and the Boston Gazette published the cartoon on March 26, 1812, christening the creature a “Gerry-mander.”¹²

The scheme worked. Federalists won a majority of the popular vote in the 1812 elections, but the map delivered roughly two-thirds of the legislative seats to Jeffersonian Republicans. Gerry himself lost his reelection bid that year. One footnote persists in the pronunciation: Gerry said his own name with a hard G, though modern speakers almost universally use a soft one.¹²

The Two Techniques Behind Every Example

Two centuries of practice have reduced gerrymandering to a pair of moves, usually combined. Packing concentrates the opposing party’s voters into as few districts as possible; those seats are won by enormous margins while the party’s strength is wasted everywhere else.³ Cracking spreads the opposing party thinly across many districts so its voters fall just short of a majority in each one.⁴ The examples below are variations on those two moves, applied first to race and later, with computer assistance, to partisanship.

Tuskegee’s 28-Sided City Limits: Gomillion v. Lightfoot (1960)

One of the most brazen gerrymanders in American history was not a legislative district at all. In 1957, the Alabama legislature redrew the boundaries of Tuskegee from a simple square into an irregular 28-sided figure that removed all but four or five of the city’s roughly 400 Black voters while excluding zero white voters.⁵

Charles Gomillion, a professor at what is now Tuskegee University, led the challenge. In a unanimous 1960 decision, the Supreme Court held that the boundary manipulation violated the Fifteenth Amendment. Justice Felix Frankfurter wrote that the amendment “nullifies sophisticated as well as simple-minded modes of discrimination.”⁶ The boundaries were reversed the following year, and the case became part of the legal foundation for the Voting Rights Act of 1965.⁷

The Interstate 85 District: Shaw v. Reno (1993)

After the 1990 census gave North Carolina a twelfth congressional seat, the U.S. Department of Justice pushed the state to create a second majority-Black district. Congressional District 12 stretched roughly 160 miles along the Interstate 85 corridor and was, for much of its length, no wider than the highway itself. It crossed ten counties. One legislator quipped that “if you drove down the interstate with both car doors open, you’d kill most of the people in the district.”⁸

Five white North Carolina voters challenged the district. In a 5–4 decision by Justice Sandra Day O’Connor, the Supreme Court held that redistricting so “bizarre on its face that it is unexplainable on grounds other than race” demands strict scrutiny under the Fourteenth Amendment’s Equal Protection Clause.⁹ The case established that race-based line drawing could be unconstitutional even when intended to benefit minority voters.

Georgia’s 260-Mile District: Miller v. Johnson (1995)

Two years later the Court confronted Georgia’s Eleventh Congressional District, which connected metropolitan Atlanta with coastal areas 260 miles away to form a majority-Black seat. The district spanned nearly 6,800 square miles, and the Court called it a “geographic monstrosity” whose makeup told “a tale of disparity, not community.”¹⁰

In another 5–4 ruling, Justice Anthony Kennedy wrote that when race is the “predominant, overriding factor” in drawing district lines, the plan is subject to strict scrutiny, and a district need not look bizarre on its face to be struck down. The Court also criticized the Justice Department’s “maximization policy” of pressuring states to create as many majority-minority districts as possible, holding that this exceeded the purpose of the Voting Rights Act.¹¹

Texas 2003: A Mid-Decade Redraw and the Killer D’s

Redistricting normally happens once per decade, after the census. In 2003 Texas Republicans broke that pattern. After winning the state House, Senate, and governor’s mansion, U.S. House Majority Leader Tom DeLay engineered a mid-decade redrawing of Texas’s 32 congressional districts, five years before the next census, designed to convert the GOP’s statewide majority into a commanding congressional delegation.¹²

To block the plan, 51 Texas House Democrats fled to Ardmore, Oklahoma, breaking quorum. Supporters called them the “Killer D’s.” House Speaker Tom Craddick sent state troopers to find and return them.¹³ The walkout failed and the map passed. An aide to Republican congressman Joe Barton described it in an email as “the most aggressive map I have ever seen,” noting senior Democrat Martin Frost’s district had been eliminated and other Democratic incumbents had been “drawn together in a Republican district.”¹²

The legal challenge reached the Supreme Court as League of United Latin American Citizens v. Perry in 2006. The Court declined to rule mid-decade redistricting inherently unconstitutional. But in a 5–4 vote, Justice Kennedy concluded that the redrawing of District 23 violated Section 2 of the Voting Rights Act by diluting the power of an emerging Latino majority to protect a Republican incumbent. The state’s proposed remedy, a new District 25 stretching 300 miles to combine two unrelated Latino communities, was found too non-compact to count.¹⁴¹⁵

Pennsylvania 2011: The First State-Court Partisan Reversal

Pennsylvania’s 2011 congressional map, drawn by the Republican-controlled legislature and signed by Governor Tom Corbett, produced an “enduring 13–5 advantage for the Republican party” in the state’s congressional delegation.¹⁶ In 2017, the League of Women Voters and a group of Democratic voters challenged it under the state constitution’s Free and Equal Clause and its protections for equal treatment, expression, and association.

On January 22, 2018, the Pennsylvania Supreme Court declared the map an unconstitutional partisan gerrymander. It was the first time a state court had successfully struck down a map on those grounds.¹⁶ When Governor Tom Wolf rejected the legislature’s proposed replacement, the court drew its own remedial map with the help of Stanford law professor Nathaniel Persily. The court-drawn map was used for the 2018 midterms, and the U.S. Supreme Court denied certiorari in October 2018.¹⁷

Wisconsin’s Assembly Map and Gill v. Whitford

Wisconsin’s 2011 state assembly maps, drawn by the Republican legislature, were among the most studied gerrymanders in history. Democrats won a majority of the statewide assembly vote in 2012 and 2014, yet Republicans held 60 of 99 seats.¹⁸ A federal panel struck down the maps in 2016.

The Supreme Court never reached the merits. In a unanimous June 2018 ruling by Chief Justice John Roberts, the Court held that the plaintiffs lacked standing because they had alleged only a generalized statewide injury rather than a concrete, district-specific harm.¹⁹ The case was sent back to the lower court and ultimately dismissed in July 2019.¹⁸

North Carolina’s Recurring Fight and the Hofeller Files

No state has produced more gerrymandering litigation. After the 2010 census, a Republican legislature packed Black voters into two congressional districts. In Cooper v. Harris (2017), the Supreme Court affirmed that the First and Twelfth Congressional Districts were unconstitutional racial gerrymanders, holding that race-based sorting is illegal even when used as a proxy for partisan advantage.²⁰ In Common Cause v. Lewis (2019), a state court struck down the legislature’s 2017 replacement state maps as illegal partisan gerrymanders under the North Carolina Constitution and ordered new maps drawn without partisan data.²¹

The scope of the enterprise came into view in 2019, when more than 100,000 files belonging to Republican redistricting operative Thomas Hofeller were unsealed after his death. His daughter Stephanie recovered at least 70,000 files from external hard drives and USB sticks, documenting redistricting work in North Carolina, Texas, Arizona, Florida, Virginia, Mississippi, and other states. Hofeller collected granular data on voting patterns by race, studied individual dormitories at North Carolina A&T State University to identify students who might lack qualifying voter ID, and warned GOP operatives that “emails are the tool of the devil.”²²²³

The North Carolina cycle continued after the 2020 census. The state supreme court struck down a 2021 congressional map, and a court-ordered replacement produced a 7–7 partisan split in 2022. After the court’s composition changed, the justices reversed course and allowed the legislature to redraw the lines. The new map helped flip three Democratic seats to Republicans in 2024.³

Ohio’s Defied Commission

In 2018, Ohio voters approved a constitutional amendment banning extreme partisan gerrymandering with 75% support.²⁴²⁵²⁶ The commission ignored the rulings, and a federal panel allowed the unconstitutional maps to be used for the 2022 elections due to timing. Former Chief Justice Maureen O’Connor led a 2024 ballot campaign, Issue 1, to replace the commission with an independent citizens panel. It was defeated, with 53.7% of voters rejecting it.²⁷

Rucho v. Common Cause (2019): Federal Courts Step Back

On June 27, 2019, the Supreme Court ruled 5–4 in Rucho v. Common Cause that partisan gerrymandering claims are “political questions” beyond the reach of federal courts. Chief Justice Roberts, writing for the majority, held there are no “judicially discoverable and manageable standards” for determining when partisan line-drawing has gone too far, and emphasized that the Constitution does not require proportional representation.²⁸ The ruling vacated lower-court decisions striking down congressional maps in North Carolina and Maryland, but noted that state courts applying state constitutions, independent commissions, and congressional legislation remained available paths.²⁹

The 2020s Cycle

The redistricting that followed the 2020 census produced some of the most lopsided maps in modern history. Analysis using algorithm-generated simulations of thousands of compliant maps found that post-2020 gerrymandering gave Republicans a nationwide advantage of roughly 16 House seats heading into 2024.³⁰ A few examples show the shape of the cycle:

In Tennessee, Republicans eliminated Nashville’s sole safe Democratic seat by splitting the city among three districts, producing a 9–0 Republican delegation.
In Florida, Governor Ron DeSantis’s preferred map converted a 16–11 Republican advantage into a 20–8 one, far exceeding simulated fair-map benchmarks.
In Texas, 25 of 38 congressional seats leaned Republican by 15 or more percentage points; Democrats held 13 seats against a simulated fair-map benchmark of 18.
In Illinois, Democrats drew maps producing a 14–3 delegation edge, where simulations suggested Republicans should hold about six seats.³⁰

Allen v. Milligan and Louisiana v. Callais

In 2023 the Supreme Court surprised many observers by upholding a Voting Rights Act challenge to Alabama’s congressional districts. Black voters made up 27% of the state’s voting-age population but were packed and cracked into a single majority-Black district out of seven. In Allen v. Milligan, a 5–4 decision led by Chief Justice Roberts, the Court affirmed a lower-court finding that the map likely violated Section 2 and ordered Alabama to create a second district where Black voters could elect their preferred candidates. The ruling reaffirmed the framework from Thornburg v. Gingles (1986) and rejected Alabama’s proposed “race-neutral benchmark” standard.³¹³²

The victory proved short-lived. On April 29, 2026, the Supreme Court ruled 6–3 in Louisiana v. Callais that Louisiana’s 2024 congressional map, which had created a second majority-Black district under court order, was itself an unconstitutional racial gerrymander. Writing for the majority, Justice Samuel Alito held that Section 2 compliance can in principle justify race-conscious redistricting but did not do so here because Section 2 had not actually required the additional district.³³ The decision raised the bar for future VRA redistricting claims by requiring plaintiffs to control for partisan affiliation when demonstrating racial bloc voting, and by requiring illustrative alternative maps to accommodate a state’s “specified political goals,” including protection of incumbent margins. Justice Elena Kagan’s dissent argued that the majority had rendered Section 2 “all but a dead letter.”³⁴ Shortly afterward, the Supreme Court vacated a federal court’s ruling that Alabama’s replacement map had been drawn with discriminatory intent, remanding in light of Callais.³¹

Voting rights advocates have described Callais as the final blow to the federal enforcement architecture of the Voting Rights Act, following Shelby County v. Holder (2013), which struck down the preclearance system, and Brnovich v. DNC (2021), which narrowed non-redistricting applications of Section 2.³⁵³⁶

Independent Commissions and the Shift to State Courts

Reform has moved to the states. As of 2026, Alaska, Arizona, California, Colorado, Idaho, Michigan, Montana, and Washington use independent commissions whose members are neither legislators nor elected officials.³⁷ Arizona established its commission by ballot initiative in 2000; California followed with a 14-member citizen commission through a 2008 initiative; Michigan voters approved a 13-member commission in 2018 with members randomly selected from applicant pools.³⁸ Ohio’s 2024 measure failed, and Utah’s legislature repealed an independent redistricting process before a state court ruled the repeal unconstitutional.³⁹

With federal courts largely closed to both partisan and VRA-based gerrymandering claims, at least ten state supreme courts have asserted authority to adjudicate partisan gerrymandering disputes under their own constitutions, while four have declined.³⁹ The fight over who draws the lines, and how, is being waged state by state.

1
Library of Congress. Gerrymandering: The Origin Story
2
Massachusetts Historical Society. The Gerrymander
3
Brennan Center for Justice. Gerrymandering Explained
4
Princeton Gerrymandering Project. Redistricting Information
5
Justia. Gomillion v. Lightfoot, 364 U.S. 339
6
Oyez. Gomillion v. Lightfoot
7
Zinn Education Project. Gomillion v. Lightfoot
8
Justia. Shaw v. Reno, 509 U.S. 630
9
Oyez. Shaw v. Reno
10
Oyez. Miller v. Johnson
11
Justia. Miller v. Johnson, 515 U.S. 900
12
Spectrum News. A Brief History of Texas Gerrymandering
13
Texas Tribune. Texas Redistricting Walkout
14
Justia. LULAC v. Perry, 548 U.S. 399
15
Oyez. LULAC v. Perry
16
Brennan Center for Justice. Pennsylvania Supreme Court Confirms State’s Congressional Map Is Illegal
17
Brennan Center for Justice. League of Women Voters of Pennsylvania v. Commonwealth of Pennsylvania
18
Brennan Center for Justice. Gill v. Whitford
19
Justia. Gill v. Whitford, 585 U.S.
20
Brennan Center for Justice. SCOTUS Upholds Decision Finding Gerrymandering in North Carolina
21
Common Cause. Common Cause v. Lewis
22
Common Cause. The Hofeller Files
23
The New Yorker. The Secret Files of the Master of Modern Republican Gerrymandering
24
Ohio Capital Journal. State Supreme Court Dismisses Redistricting Cases
25
Brennan Center for Justice. Timeline of Ohio’s Gerrymandered Maps
26
Supreme Court of Ohio. Nieman v. LaRose, Slip Opinion No. 2022-Ohio-2471
27
Ohio Capital Journal. Ohio Voters Reject Issue 1
28
U.S. Supreme Court. Rucho v. Common Cause, 588 U.S.
29
Brennan Center for Justice. Rucho v. Common Cause
30
Brennan Center for Justice. How Gerrymandering Tilts the 2024 Race for the House
31
NAACP Legal Defense Fund. Allen v. Milligan
32
U.S. Supreme Court. Allen v. Milligan, Nos. 21-1086 and 21-1087
33
U.S. Supreme Court. Louisiana v. Callais, 608 U.S.
34
SCOTUSblog. In Major Voting Rights Act Case, Supreme Court Strikes Down Redistricting Map
35
Harvard Kennedy School. What Louisiana v. Callais Means for the Voting Rights Act
36
Brennan Center for Justice. After Louisiana v. Callais, Here’s Proof of Just How Bad Voting Rights in America Are
37
Loyola Law School. Who Draws the Lines
38
Campaign Legal Center. Independent Redistricting Commissions
39
Stateline. As Supreme Court Pulls Back on Gerrymandering, State Courts May Decide Fate of Maps