Memorandum in Support of Proposed Redistricting Plan of Floridacensusvalidator.blob.core.windows.net... · 2011-05-27 · addition of the black population of St. Petersburg is most

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Memorandum in Support of Proposed Redistricting Plan of Florida

Nicholas Ortiz*

I. Introduction

Various considerations influenced my decisions of how to divide Florida’s congressional

districts. At the more macroscopic level, I sought to draw a map that reflects how I believe

Florida divides geographically and culturally. This division is clearly a personal, subjective

notion of the state’s and some cities’ internal compositions, which is informed by my having

lived in Florida for thirteen years. Although subjective, it is nevertheless influenced by objective

features of the state, which I hope renders my impression of the state’s internal makeup generally

agreeable. While my close relationship with the state was a considerable asset in drawing the

plan, it is also possible that the locations of my residences may at times unintentionally imbue

the plan map with some regional biases or misperceptions in the state’s makeup. With the lone

exception of a recent three-month period during which I lived in downtown Miami, the entire

time that I lived in Florida, I resided in Fruit Cove, a suburb of Jacksonville in St. Johns County.

Beyond my mental sketch of how the state looks, traditional districting principles guided

the boundaries of my proposals. In particular, § 20 of Article III of the Florida Constitution

instructs that congressional districts should be drawn compactly and with respect for geographic

boundaries and political boundaries.1 The constitution does not prioritize any one of those

considerations over another.2 In practice, complying with this requirement generally meant that I

endeavored to create compact districts that utilized county lines, major roads, bridges, rivers, and

lakes as district boundaries. I tried to keep entire counties together as often as possible except

when compactness would appreciably suffer. I also sought to not divide cities when possible.

* J.D. Candidate, Columbia University. The author may be reached by email at [email protected].

1 See Fla. Const. art. III, § 20(b).

2 § 20(c).

2

As § 20 indicates that a redistricting plan should not prioritize political boundaries over

otherwise preferable geographic boundaries, the proposed plan is not precisely a “good

government” plan that emphasizes compactness and respect for political subdivision lines.

Hence, I have described it as a “portfolio” plan.

Florida’s constitution contains an additional requirement that “[n]o apportionment plan or

individual district shall be drawn with the intent to favor or disfavor a political party or an

incumbent . . . .”3 I did not utilize political data in constructing my proposed districts. Except

when relevant to determining the plan’s compliance with the Voting Rights Act (“VRA”) or the

Florida Constitution, I did not predict or otherwise consider the voting tendencies of the

electorate in different areas. I do not know the political consequences of my proposals, and even

the guesswork in which I occasionally need to engage I fully acknowledge may be wholly

inaccurate. I also did not consider the location of the residence of any incumbent. Additionally,

I largely disregarded the existing district lines in constructing my proposed districts, as

respecting existing lines for no reason other than that they preceded this proposal would

uselessly increase the advantages of incumbency. However, the proposed districts do not

actively seek to depart from existing district lines, except to the extent that existing district lines

depart from neutral districting principles. Indeed, several proposed districts overlay very closely

with existing district lines, although the reasons for such results are apolitical. Similarly

constructed districts resulted from an effort to comply with the Voting Rights Act (“VRA”), the

Florida Constitution, or traditional districting principles.

Florida gained two congressional districts after the most recent census. The state now

has 27 congressional seats allocated to it. I should note that I did not seek to “add” the new

districts in any particular part of the state for two reasons. First, I did not seek to benefit any

3 § 20(a).

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portion of the state at the expense of any other in constructing this plan. I do not believe any part

of the state is more deserving of an additional district or two than any other part, unless

demographics so dictate. Second, the notion that one who makes a redistricting plan has

discretion where to add a district or two seems to misunderstand the principle that congressional

districts must be equipopulous. Congressional districts surround wherever the state’s population

is located. The demographic trends of the state determine where districts are “added.” If one

city in Florida previously had a population of 1/27 of the state, but since 2000 its population has

grown to 3/27 of the state, that city would necessarily contain at least three districts under the

new plan, whereas it previously only needed to include one district.4 New districts “should,” and

do, go wherever the population is.5 That is the premise and consequence of the Equal Protection

Clause’s requirement of “one person, one vote.” As such, accommodating two new districts did

not create any problems in crafting this redistricting plan.

Florida’s current congressional map as a whole and many of Florida’s current

congressional districts are commonly regarded as diverging strongly from traditional districting

principles in order to advantage the Republican Party.6 This perception may have motivated the

4 Or, viewed differently, suppose Florida had had only one congressional district under the current plan and it now

merits two congressional districts. If Florida then is divided in half to accommodate the new district, where has the

new district been added? 5 Obviously the borders of the districts are malleable, but to the extent one considers the adding of a district to

include creating an additional jutting appendage into an area, then one could presumably create as many as 27

districts throughout the state. But as districts must be compact, this is an impermissible way to “add” a district. In

any event, the creation of new jutting appendages does not appear to be what most mean when they speak of adding

a newly received district in some part of the state as opposed to another. Indeed, that could be done irrespective of

whether the state had gained an additional district or two. 6 See, e.g., Fred Grimm, Governor Has No Problem Ignoring Will of Voters, MIAMI HERALD, Jan. 21, 2011

(“[B]latant gerrymandering . . . has long characterized the state’s legislative and congressional districts.”), available

at http://www.miamiherald.com/2011/01/26/2036348/governor-has-no-problem-ignoring.html#ixzz1KnHGvKfn;

Leon W. Russell & J. Gerald Heber, Put an End to Gerrymandering in Florida, ST . PETERSBURG TIMES, Aug. 10,

2010 (“Florida has fewer competitive elections than almost any state in the union .”), available at

http://www.tampabay.com/opinion/columns/put-an-end-to-gerrymandering-in-florida/1114190; Editorial, One-Sided

Races, ORLANDO SENTINEL, July 30, 2004 (opining that the majority-Republican legislature successfully packed

Democrats into as few districts as possible leading to the result that only one of Florida’s 25 congressional districts

under the current map is “truly competitive”), available at http://articles.orlandosentinel.com/2004-07-

30/news/0407300044_1_gerrymandering-districts-in-florida-lawmakers.

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successful ballot initiative to amend the Florida Constitution during the 2010 congressional

elections, which resulted in the addition of Sections 20 and 21 to Article III of the state

constitution. Section 21 mirrors Section 20’s requirements but applies to the process of

reapportioning state legislative districts.

Although there is indeed significant overlap in several districts under the current and

proposed plans, as others have opined, many districts under the existing plan fare poorly under

neutral districting principles. For example, the current congressional District 11 divides St.

Petersburg by carving out the tip of the St. Petersburg peninsula, which has a predominantly non-

Hispanic black (hereinafter “black”) population.7 In doing so, the district crosses Tampa Bay in

order to divide Pinellas County, the city of St. Petersburg, and the St. Petersburg peninsula. By

reaching into St. Petersburg, the district sacrifices compactness. As the district is not compact

and disrespects major political and geographic boundaries, it violates all three principles

commanded by the new redistricting amendments. The district does not appear to have been

crafted to comply with the VRA or another state law.8 Rather it seems that the purpose behind

grabbing the St. Petersburg population was to create a safe Democratic district from heavily

Democratic populations in Tampa and St. Petersburg.9 The plan I propose keeps the peninsula

and St. Petersburg undivided; it divides Pinellas County only once in order to meet the

requirements of population equality.10

7 See Figure 1 of Appendix.

8 One justification may have been to create a black and Hispanic coalition district. This explanation is

underwhelming, however. Their unified electoral strength is more aptly described as perhaps a combined influence

district. Blacks only represent 27.3% of CVAP and Hispanics only represent 21.3% of CVAP. Moreover, since

2000, the representative from current District 11 appears to have been the white majority’s candidate of choice. The

addition of the black population of St. Petersburg is most likely explained as being motivated by the goal of creating

a very safe Democratic district. 9 Of the five congressional elections from 2002-2010, the Democratic nominee won an uncontested election once

and four elections with a total vote share of 85.82, 69.65, 71.66, and 59.64. 10

See Figure 2 of Appendix.

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II. Legal Compliance

Three sources of law imposed significant constraints on this redistricting plan. They are

the United States Constitution, the Voting Rights Act, and the Florida Constitution. The

proposed redistricting plan complies with the obligations and restraints imposed by those laws.

A. Federal Constitutional Requirements

1. One Person, One Vote

The Equal Protection Clause of the 14th Amendment to the United States Constitution

requires that congressional districts contain populations that are as close to perfect equality “as is

practicable.”11 Although the Supreme Court has noted that the relevant population figure that a

plan seeks to equalize need not be total population,12 uncertainty remains nationally as to what

alternative population variables may be used to evaluate a plan’s compliance with the “one

person, one vote” principle.13 The Eleventh Circuit has not addressed the issue. Accordingly,

this proposal equalizes total population figures, which the Court has approved as a valid measure

of population equality.14

The U.S. Census Bureau reported Florida’s total population in 2010 at 18,801,310

persons. That population warrants 27 congressional districts. The ideal district size is

696,344.81. To achieve the least deviation as is possible from perfect population equality, 22

districts must contain 696,345 persons and five districts must contain 696,344. The proposed

plan distributes Florida’s population in that manner.

11

Karcher v. Daggett, 462 U.S. 725, 730 (1983). 12

See Burns v. Richardson, 384 U.S. 73, 91-92 (1966). 13

Compare Garza v. County of Los Angeles, 918 F.2d 763 (9th Cir. 1990) (concluding that citizens of voting age

population is not a proper standard for population equality), with Daly v. Hunt, 93 F.3d 1212, 1227-28 (4th Cir.

1996) (permitting the political branches to decide which measure of population to equalize), and Chen v. City of

Houston, 206 F.3d 502, 523 (5th Cir. 2000) (same). Accord Chen v. City of Houston, 532 U.S. 1046, 1046 (2001)

(Thomas, J., dissenting) (dissenting from denial of petition for writ of certiorari because “as long as we sustain the

one-person, one-vote principle, we have an obligation to explain to states and localities what it actually means.”) 14

See, e.g., Burns, 384 U.S. at 91.

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2. Racial Gerrymandering

The Equal Protection Clause also prohibits congressional districts that include unjustified

racial gerrymandering. If considerations of race predominate in the drawing of a district,

subordinating traditional districting principles, strict scrutiny analysis applies and the district will

not be upheld as valid unless it is narrowly tailored to satisfy a compelling state interest.15

Where this redistricting plan deviates from traditional districting principles, it does so by

narrowly tailoring districts that further the state’s compelling interests of compliance with the

VRA and the Florida Constitution.

a. The State’s Interest

At least two of the proposed districts subordinate traditional districting principles in order

to comply with §§ 2 and 5 of the VRA and Article III of the Florida Constitution, which has a

non-retrogression requirement that parallels that of § 5 of the VRA.16 In Section II.B below I

argue that compliance with § 2 compels the drawing of each of the majority-minority districts. If

§ 2 of the VRA does not require one or more of the districts, Article III of the Florida

Constitution would require them to prevent retrogression.

Although the Court has never held so in any case, a majority of the current justices have

agreed that compliance with §§ 2 and 5 of the VRA is a compelling state interest.17 Therefore,

racial gerrymandering to comply with §§ 2 or 5 of the VRA appears permissible so long as it is

narrowly tailored.

Whether compliance with Article III supplies a compelling state interest is uncertain,

although there are good reasons to believe that it does. By amending Article III of its 15

See Miller v. Johnson, 515 U.S. 900, 916 (1995); Shaw v. Reno, 509 U.S. 630 (1993). 16

Section 5 of the VRA applies only to certain counties of Florida. Only Collier, Hardee, Hillsborough, Hendry,

and Monroe Counties are subject to § 5. See Section 5 Covered Jurisdictions, U.S. DEP’T OF JUSTICE (last visited

Apr. 30, 2011), http://www.justice.gov/crt/about/vot/sec_5/covered.php. 17

See League of United Latin Am. Citizens v. Perry, 548 U.S. 399, 518-19 (2006) (Scalia, J., dissenting); Bush v.

Vera, 517 U.S. 952, 976-77 (1996) (plurality opinion).

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constitution to add § 20(a), Florida imposed on the entire state the anti-retrogression redistricting

requirements with which jurisdictions covered by § 5 of the VRA must comply. The Court

believes § 5 of the VRA offers a compelling purpose18 even though the Court has doubted the

utility of the triggering mechanism.19 Indeed, the problematic aspect of § 5 to these justices is

that the triggering mechanism both is imprecise and represents a potential affront to state

dignity.20 Therefore, the Court has determined that the VRA offers a compelling purpose despite

its triggering mechanism’s imprecision and imposition on state sovereignty. As such, when a

state voluntarily decides that it should protect racial or language minorities’ ability to participate

in the political process in the same manner prescribed by § 5 of the VRA, presumably the Court

would regard the state’s interest in such a circumstance at least as compelling as when Congress

directs that the state act in such a manner.

Indeed, a refusal to recognize the state’s interest in complying with a successful ballot

initiative substantially similar to § 5 would arguably itself represent an affront to Florida’s

important sovereign interests. The citizens of Florida voted to amend Article III to include § 20

presumably because they believed it would improve the state’s democratic functioning by

increasing the ability of minorities to participate in the political process. Therefore, a

determination that compliance with Article III does not represent a compelling state interest

would be inconsistent with Court precedents respecting both the compelling value of the VRA’s

purpose and of states’ interests in self-governance.21

18

See League of United Latin Am. Citizens v. Perry, 548 U.S. 399, 518-19 (2006) (Scalia, J., dissenting); Bush v.

Vera, 517 U.S. 952, 976-77 (1996) (plurality opinion). 19

See N.W. Austin Util. District Number One v. Holder, 129 S. Ct. 2504, 2511-12 (2009); id. (Thomas, J.,

concurring in part and dissenting in part). 20

Id. 21

In any event, if § 2 requires the districts, as I argue it does, whether compliance with Article III offers a

compelling state interest to justify narrowly tailored racial gerrymandering would be a moot question.

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b. Tailoring

In an effort to narrowly tailor the districts to the requisites of the VRA and § 20(a), I

sought to make the majority-minority districts as compact as practicable and to increase the

extent to which the districts’ borders relied on existing political or geographic boundaries.

Florida’s current District 23, for example, contained four appendages reaching from the state’s

interior to pockets of black populations in Fort Pierce, West Palm Beach, Fort Lauderdale, and

Miramar.22 The distance from Miramar to Fort Pierce spans approximately 120 miles. I was

able to craft a majority black district that eliminates the outermost appendages of current District

23 and which spans instead from West Palm Beach to Fort Lauderdale, a distance of

approximately 50 miles.23 This proposed district, District 9, also captures a heavily black

population in Belle Glade, in the western half of Palm Beach County, as the current District 23

does. I also substantially improved the compactness of the other majority-minority districts in

South Florida.24

Meanwhile, where increasing the compactness of certain other majority-minority districts

was particularly difficult I sought to improve the districts’ adherence to other traditional

districting principles. In order to create a district whose citizens of voting age population

(“CVAP”) are a majority black in the northern half of Florida, a district must stretch from

Jacksonville to Gainesville to Orlando, a stretch of approximately 180 miles. Current District 3

captures these populations.25 Although increasing that district’s compactness was nearly a

hopeless endeavor, I was able to improve the district’s adherence to traditional districting

principles by at least having its eastern border perfectly follow the St. Johns River from

22

See Figure 3 of Appendix. 23


See discussion infra Section III.A. 25


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Jacksonville to Orlando.26 As the St. Johns River also functions as a border between counties to

the east and west of it, aligning the proposed district, District 26, along the river also improved

the district’s respect for existing political boundaries. Current District 3 does not follow the St.

Johns River exactly. It reaches back and forth over the river to grab substantial portions of

Putnam County, and abandons the river as a border entirely in Volusia County.

I also endeavored to improve the tailoring of proposed District 26 by seeking to create an

alternative district incorporating most of the black population of current District 3 that would

better adhere to traditional districting principles. The alternative I sought to create stretched

along Florida’s northern border from Jacksonville to Tallahassee. Such a district would have

improved the district’s cultural compactness, as the northern portion of the state is typically

regarded as featuring a distinctively Southern culture. Orlando is somewhat of the crossroads of

the state, where the Southern elements of Florida begin to mix with the state’s Hispanic

influence, more characteristic of South Florida. Orlando is also well known for its popular

tourist attractions, which are less numerous and significant in North Florida. Nevertheless, I

could not create such a district with a majority black VAP or CVAP. The highest CVAP

percentage I could create with such a district was approximately 47%. The current District 3 has

a CVAP of 50.8%. Additionally, the district I sought to create would have had to suffer

markedly in compactness and in its respect for political and geographic boundaries. The district

would have had to feature many southwardly extending appendages that would have made it

much more of an eyesore than even the current District 3. Indeed, to the extent appearances are

relevant, this would-be district would have had an almost haunting look, ominously reaching

towards the rest of the state. The compactness of several neighboring districts would have

suffered considerably as a result as well.

26


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Lastly, I considered as an alternative to proposed District 26 creating a coalition district

in and around Orlando of blacks and Hispanics. Puerto Ricans comprise a majority of Central

Florida’s Hispanic population.27 Cubans represent only 7 percent of the Hispanic population in

Central Florida. 28 Unlike Cubans, who vote mostly Republican,29 Central Florida’s Puerto

Rican population votes heavily Democratic, voting for Vice President Al Gore and Senator John

Kerry in the 2000 and 2004 elections at a rate of 60% and 66%, respectively.30 Therefore, while

it would be inappropriate to seek to join blacks and Cubans into a coalition district, it arguably

would not be inappropriate to join blacks and Puerto Ricans into a coalition district.31 Because

of the apparent substantial similarity in voting patterns of Central Florida’s black and and Puerto

Rican population, a coalition district could have been created here. The would-be coalition

district would have been approximately 40% Hispanic CVAP and 20% black CVAP.

If I had created that Central Florida coalition district, I would have also likely created a

black opportunity district of between 45 and 47% black CVAP running from Jacksonville to

Gainesville to Tallahassee. The Hispanic CVAP of that hypothetical district would have been

between 2 and 4%. One possible shortcoming I perceived in a Jacksonville-to-Tallahasee

opportunity district is the frequency with which it would have “performed” to elect the

representative of choice of the black voters. Assuming racial polarization in voting, the majority

non-black voters in the district would vote predominantly Republican, or else otherwise for a

27

JORGE DUANY & FÉLIX V. MATOS-RODRÍGUEZ, CENTRO DE ESTUDIOS PUERTORRIQUEÑOS AT THE CITY UNIV. OF

N.Y., PUERTO RICANS IN ORLANDO AND CENTRAL FLORIDA, POLICY REPORT NO. 1 (2006), available at

http://www.centropr.org/documents/working_papers/FloridaBrief(F).pdf. 28

Maria T. Padilla, Puerto Ricans Stream Into Area, ORLANDO SENTINEL, Mar. 24, 2011, available at

http://articles.orlandosentinel.com/2001-05-24/news/0105240302_1_ricans-central-florida-hispanics/2. Central

Florida’s remaining Hispanic population is of Mexican, Central American, and South American origin. Id. 29

DUANY & MATOS-RODRÍGUEZ, supra note 23, at 22. 30

Id. at 4. 31

Under the Eleventh Circuit’s § 2 jurisprudence predating Bartlett v. Strickland, 129 S. Ct. 1231 (2009), discussed

infra Part II.B.1, a state may create a cross-over or coalitional district pursuant to § 2. See Concerned Citizens of

Hardee County v. Hardee County Bd. of Comm’rs , 906 F.2d 524, 526 (11th Cir. 1990) (“Two minority groups (in

this case blacks and hispanics) may be a single section 2 minority if they can establish that they behave in a

politically cohesive manner.”).

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candidate other than that preferred by the black population. Indeed, all of North Florida’s

current congressional districts, with the exception of District 3, are occupied by a Republican

representative. All of the districts currently held by Republicans appear to be safely Republican;

only current District 2, one of the districts embracing Tallahassee, has been held by a Democrat

this past decade.

One consideration counseling in favor of creating the coalition and opportunity districts is

the fact that Florida’s VAP is approximately 21.1% Hispanic, although under my proposed plan,

only three of the state’s 27 districts (11.1%) would be majority Hispanic. Moreover, those

districts that are majority-Hispanic are all located in South Florida, where the Cuban-American

population predominates over other Hispanic populations. However, Cubans consist of only

36% of Florida’s Hispanics of VAP, or 7.6% of the state’s total population.32 Therefore, with

three majority-Hispanic districts in South Florida and none elsewhere, Florida’s Cuban

population, which votes dissimilarly from the state’s non-Cuban Hispanic population,33 is

disproportionately overrepresented with 11.1% of the state’s representatives. The remainder of

the state’s non-Cuban Hispanic VAP—nearly as numerous at 13.5% of VAP as the state’s non-

Hispanic black population, which is 13.7% of VAP—would lack a single district that would

likely elect the representative of the group’s choice.

Nevertheless, I chose to retain the Jacksonville-to-Orlando majority black district because

I sought to avoid undoing a safely performing black district,34 which would have rendered

Florida’s black population disproportionately underrepresented if the Jacksonville-to-Tallahassee

district did not perform. I feared running afoul of Article III’s proscription against redistricting 32

PEW HISPANIC CENTER, THE HISPANIC ELECTORATE IN FLORIDA (2004), available at

http://pewhispanic.org/files/factsheets/9.pdf. 33

DUANY & MATOS-RODRÍGUEZ, supra note 23, at 22. 34

Current District 3 is held by Democrat Corrine Brown. In the past five elections Brown has won three times

without opposition by a Republican candidate and with 63.0% and 59.3% of the votes cast in the 2010 and 2002

elections, respectively.

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plans that “diminish the[] ability [of racial minorities] to elect representatives of their choice.”

Exchanging a safe black district in favor of a likely-Hispanic district and a black opportunity

district would probably be viewed as a retrogressive tradeoff as to the black population that

diminishes the ability of blacks in Central and North Florida to elect representatives of their

choice.

In each majority-minority district, I sought to create the most compact district possible

that accorded significant respect for political and geographic boundaries. I considered many

alternative schemes to those that I ultimately proposed. The proposed majority-minority districts

are the districts that I believe best adhere to traditional districting principles while complying

with the VRA and Article III of Florida’s Constitution. Accordingly, the districts are narrowly

tailored to the state’s compelling interest of complying with the VRA and the state constitution.

I argue in Part II.B-C that the VRA and Florida’s Constitution require the majority-minority

districts that I propose.

B. Federal Statutory Requirements

1. Voting Rights Act § 2

Under § 2 of the VRA, a majority-minority district must be created when a minority

group is “sufficiently large and geographically compact to constitute a majority” in a single-

member district, the minority group is “politically cohesive,” and the white majority votes

“sufficiently as a bloc to enable it . . . usually to defeat the minority’s preferred candidate.”35

The requirement that minority populations be sufficiently compact includes a requirement that

the populations be culturally compact.36

35

Thornburg v. Gingles, 478 U.S. 30, 50 (1986). 36

See League of United Latin Am. Citizens v. Perry, 548 U.S. 399 (2006).

13

Additionally, it must be the case that under the “totality of circumstances,” minorities are

less able to participate in the political process than the white majority.37 A plan will be valid,

therefore, that tends to “thwart the historical tendency to exclude [minorities], not expand or

perpetuate it.”38 One particularly significant factor in evaluating this last prerequisite is the

proportionality of a minority group’s VAP relative to its percentage share of the districts in

which it represents a majority of the VAP.39 Section 2 does not require that a state create the

maximum quantity of the majority-minority districts possible, particularly when proportionality

has been achieved.40 Nevertheless, proportionality does not operate as a “safe harbor,” blessing

all redistricting plans that achieve proportionality; it is merely relevant to the totality of the

circumstances inquiry.41

Furthermore, § 2 does not require the creation of coalition or cross-over districts. 42

Section 2 only requires the drawing of districts when a single minority group constitutes more

than 50 percent of the VAP.43 Under Eleventh Circuit jurisprudence predating Bartlett, a state

may create a cross-over or coalitional district pursuant to § 2.44

The proposed plan complies with § 2. Although I did not have the necessary political

data available at my disposal, I operate under the factual premises accepted by the Supreme

Court in Johnson v. De Grandy45 that South Florida’s black and Cuban-American populations

are separately politically cohesive and that the white majority votes sufficiently as a bloc to

37

Johnson v. De Grandy, 512 U.S. 997, 1011-12 (1994). 38

Id. at 1014. 39

Id. 40

Id. 41

Id. at 1019-20 42

Bartlett v. Strickland, 129 S. Ct. 1231, 1245 (2009). 43

Id. 44

Concerned Citizens of Hardee County v. Hardee County Bd. of Comm’rs , 906 F.2d 524, 526 (11th Cir. 1990)

(“Two minority groups (in this case blacks and hispanics) may be a single section 2 minority if they can establish

that they behave in a politically cohesive manner.”). 45

512 U.S. 997 (1994).

14

typically defeat the preferred candidates of both groups.46 This analysis, therefore, presumes that

the second and third Gingles prongs are satisfied as to the black and Hispanic populations of

South Florida.

This analysis also assumes that the black populations in North and Central Florida are

politically cohesive and that the white majority votes sufficiently as a bloc to usually defeat their

candidates of choice. This project lacks the necessary political data to analyze those issues

sufficiently, but those assumptions seem appropriate.

The preponderance of the black population in the greater Miami metropolitan area is

located north of downtown Miami to the west of US-1 in a triangular region extending north only

18 miles to the Pembroke Pines area of Broward County. Proposed District 3 captures this

population without serious subordination traditional districting principles. The population is

sufficiently compact for § 2 purposes. Moreover, without this district, there would only be two

majority-black CVAP districts in Florida (7.4% of the total districts) while Florida’s black VAP

is presently 13.7%. With the district, blacks are a majority of the CVAP in 11.1% of the state’s

districts. Accordingly, § 2 compels the creation of this district.

Proposed District 9 is the second majority-black CVAP district in South Florida.

Although one may have questioned the compactness of the current District 23,47 the black

populations of proposed District 9 are limited to the greater West Palm Beach area and Fort

Lauderdale, which are both culturally similar areas and geographically very proximate.

Accordingly, proposed District 9 is sufficiently compact for § 2 purposes. Moreover, without

this district, there would only be two majority-black CVAP districts in Florida (7.4% of the total

districts) while Florida’s black VAP is presently 13.7%. With the district, blacks are a majority

46

See id. at 1024. 47

See discussion supra Part II.A.2.

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of the CVAP in 11.1% of the state’s districts. Accordingly, § 2 compels the creation of this

district.

The majority Hispanic districts in South Florida are likewise highly compact,48 and I did

not subordinate traditional districting principles in order to create them. Proposed Districts 1, 2,

and 5 were the products of my effort to create districts encompassing what I perceive to be the

most similar communities of Miami. Indeed, one would likely have to subordinate traditional

districting principles in order to not draw three majority CVAP districts from the populations in

Miami-Dade County and southern Broward County. With three majority-Hispanic districts in

the state, majority-Hispanic districts account for 11.1% of the state’s total districts, while

Hispanics are 21.1% of the population.49

Proposed District 26 is the third proposed majority black district that runs from

Jacksonville to Orlando, a distance of approximately 140 miles. The district grabs segments of

black populations in Jacksonville, Orlando, and Gainesville. Although rural areas lie between

the three cities, the black populations overwhelming reside in urbanized areas. In LULAC, the

Court explained that minority populations were insufficiently compact where they were

separated by 300 miles and had disparate “needs and interests” as a result of “differences in

socio-economic status, education, employment, health, and other characteristics.”50 Whether the

black populations in Orlando, Jacksonville, and Gainesville are comparably distinct from each

other in terms of socio-economic status, education, employment, health, and other characteristics

requires data that is unavailable to me. It is my assumption that in the aggregate they do not

share markedly dissimilar political objectives, and nothing about the characteristics of the cities

in which they reside leads me to believe otherwise. Accordingly, I believe the populations in

48

See discussion infra Part III.A. regarding the compactness of the South Florida districts. 49

But see discussion supra Part II.A.2 regarding the overrepresentation of Cuban-Americans. 50

See League of United Latin Am. Citizens v. Perry, 548 U.S. 399, 424 (2006).

16

proposed District 26 are sufficiently compact for § 2 purposes. Without proposed District 26,

there would only be two majority-black CVAP districts in Florida (7.4% of the total districts)

while Florida’s black VAP is presently 13.7%. With the district, blacks are a majority of the

CVAP in 11.1% of the state’s districts. Accordingly, § 2 requires the creation of this district.

Section 2 does not require the creation of any other majority-minority districts throughout

the state. I could not create another district elsewhere in the state that consisted of a majority

VAP or CVAP of any minority group.51

2. Voting Rights Act § 5

Under § 5 of the VRA, certain jurisdictions of the United States may not adopt a

redistricting plan that will “diminish[] the ability of any citizens of the United States on account

of race or color . . . to elect their preferred candidates of choice . . . .”52 Whether a change in a

congressional districting plan violates § 5 is determined by analyzing whether it has a

“retrogressive” effect.53 The prohibition on retrogression simply means the new plan must not

worsen the position of minorities with respect to their ability to elect their preferred candidates of

choice.54

Collier, Hardee, Hillsborough, Hendry, and Monroe Counties are subject to § 5.55 Only

Monroe, Collier, and Hendry Counties currently have at least one majority-minority district

within them.

Under the current plan, Districts 18 and 25 fall within Monroe County. Both districts are

majority Hispanic. Hispanics consist of 67.2% of VAP and 59.8% of CVAP in District 18.

51

See Bartlett v. Strickland, 129 S. Ct. 1231, 1245 (2009) (explaining that § 2 does not require the creation of a

district unless a single minority group could represent a majority of the VAP in a single district). 52

42 U.S.C. §§ 1973c(b), (d). 53

See, e.g., Reno v. Bossier Parrish Sch. Bd., 520 U.S. 471, 487 (1997). 54

See id. (applying § 5 prior to the 2006 reenactment of the VRA, which changed the operative language to “ability

to elect”). 55

See Section 5 Covered Jurisdictions, U.S. DEP’T OF JUSTICE (last visited Apr. 29, 2011),

http://www.justice.gov/crt/about/vot/sec_5/covered.php.

17

Hispanics comprise 72.2% of VAP and 65.9% of CVAP in District 25. In the proposed plan,

two majority Hispanic districts embrace Monroe County. Proposed Districts 1 and 5 have

Hispanic VAP populations of 70.6% and 77.4%, respectively. They have CVAP percentages of

65.2% and 72.1%, respectively. As Hispanics continue to consist of supermajorities—indeed

even greater supermajorities than under the current plan—in the two Hispanic districts covering

Monroe County, the current plan has not had a retrogressive effect in Monroe County.

Current District 25 also embraces Collier County. It is the only majority-minority district

in Collier County under the current map. Proposed District 5 likewise includes Collier County.

Proposed District 5’s VAP and CVAP percentages, 77.4% and 72.1% respectively, are greater

than the VAP and CVAP percentages of current District 25, which are 72.2% and 65.9%,

respectively.

Under the current plan, one majority-black district, District 23, embraces parts of Hendry

County. The black population in current District 23 is 51.8% of VAP and 54.4% of CVAP.

Under the proposed plan, District 9 reaches into Hendry County. District 9’s black population is

50.3% of VAP and 52.3% of CVAP. As blacks continue to retain modest majorities of the

majority-black district’s VAP and CVAP, the proposed scheme has not had a retrogressive

effect.

C. State Law Requirements

1. Prohibition on Retrogression

The Florida Constitution contains a restriction on redistricting scheme’s very similar to

that of § 5 of the VRA. Section 20(a) of Article III of the constitution provides that no

congressional districting scheme shall be drawn with the consequence of “diminish[ing] the[]

ability [of racial or language minorities] to elect representatives of their choice . . . .” This state

18

constitutional requirement plainly adopts the operative language of § 5 of the VRA. Unlike § 5

of the VRA, however, this state constitutional requirement is not limited to certain counties of

Florida.

As Article III was only recently amended in November 2010 to include § 20, no case law

exists interpreting § 20 to guide this application of the law. In parroting the language of § 5 of

the VRA, the law evidently requires one to examine the retrogressive effects of a plan statewide,

as if the entirety of Florida were covered by § 5.

Under the current plan, three majority-black districts exist. They have black VAP

percentages of 48.0 (District 3), 51.8 (District 23), and 53.6 (District 17). The current districts

have black CVAP percentages of 50.8 (District 3), 54.4 (District 23), and 58.1 (District 17). In

District 3, which stretches from Central to North Florida where the Hispanic population is

predominantly non-Cuban, the Hispanic VAP and CVAP percentages are 10.6 and 8.2. It is

possible the Hispanic population may vote for the black population’s candidate of choice in

District 3.

The proposed plan likewise creates three majority-black districts. The proposed districts

have black VAP percentages of 48.4 (District 26), 50.3 (District 9), and 52.2 (District 3). They

have black CVAP percentages of 51.3 (District 26), 52.3 (District 9), and 56.1 (District 3).

District 26, which stretches from Central to North Florida has Hispanic VAP and CVAP

percentages of 10.2 and 7.9. As blacks still retain a majority of CVAP in all three districts as

they did under the current plan, the plan has not had a retrogressive effect. Although the CVAP

percentages in two districts reduce slightly from 58.1 to 56.1 and 54.4 to 52.3, in both of the

proposed districts blacks retain a modest buffer from becoming less than 50% of CVAP.

Moreover, a reduction in the black populations seems unavoidable in both districts, as District 17

19

required the addition of more than 41,000 persons to achieve population equality. District 23

likewise was underpopulated by more than 12,000 persons. In any event, as blacks are still a

modest majority of both VAP and CVAP in both proposed Districts 3 and 9, the black

populations of these districts will still be able to elect the candidates of their choice, just as they

were able to do under the current plan. Therefore the proposed plan has not had a retrogressive

effect and does not violate Article III of the Florida Constitution.

In the third majority black district, the proposed plan increased the black VAP from

48.1% to 48.4% and CVAP from 50.8% to 51.3%. The Hispanic population in the third majority

black district remained substantially similar to the population in the current plan. As the

population actually increased in this third majority-black district from the current to the proposed

plan, the proposed plan has not had a retrogressive effect. Accordingly, the proposed plan has

not diminished the ability of blacks in Florida to elect representatives of their choice.56

The proposed plan also creates three majority-Hispanic districts. The VAP and CVAP

populations of each district increase from the current plan to the proposed plan.57 Therefore, the

proposed plan would not have a retrogressive effect with respect to the Hispanic population

either.

It is also worth noting that the current plan has only one other district with a Hispanic

VAP that exceeds 30%. Current District 20, which is located in South Florida, has a Hispanic

VAP of 30.2%. The proposed plan contains two districts with Hispanic VAP populations

exceeding 30%. Proposed Districts 19 and 6 have Hispanic VAP percentages of 33.4 and 31.0,

56

It is worth noting that neither the current plan nor the proposed plan contains any districts that are at least 30%

black VAP. 57

The current plan has districts with Hispanic VAP percentages of 67.2 (District 18), 72.2 (District 25), and 77.1

(District 21). The Hispanic CVAP percentages in those districts are 59.8 (District 18), 65.9 (District 25), and 73.0

(District 25). The proposed plan has districts with Hispanic VAP percentages of 70.6 (District 1), 72.5 (District 2),

and 77.4 (District 5). The Hispanic CVAP percentages in those districts are 65.2 (District 1), 66.2 (District 2), and

72.1 (District 5).

20

respectively. District 19 is located in Central Florida; District 6 is located in South Florida. The

proposed plan, therefore, creates a modest influence district for the predominantly non-Cuban

population in Central Florida that does not exist under the current plan.

2. Contiguity

The Florida Constitution also requires that districts consist of contiguous area.58

Although some proposed districts occasionally rely on narrow strips of land in order to comply

with the VRA and to avoid retrogression under Article III, the proposed districts are contiguous

in all parts. None of the districts contains any “point contiguities.” There are no unassigned

parts of the state.

III. Proposed Plan’s Adherence to Neutral Districting Principles

To effectuate the mandate of § 20(b) of Article III, I generally sought to create compact

districts that utilize existing political and geographic boundaries. With the exception of several

majority-minority districts and some districts adjacent to those majority-minority districts, the

districts in the proposed plan are typically very compact.59 In crafting boundaries, I sought to

utilize county lines, major roads, bridges, rivers, and other bodies of water as district boundaries

as often as possible. I tried to keep islands, peninsulas, and other significant geographic bodies

contained within the same district when feasible.

58

See Fla. Const. art. III, § 20(a). 59

With the lone exception of proposed District 26, each of the majority-minority districts improves compactness .

District 26 instead improved the district’s adherence to natural geographic boundaries.

21

A. Compactness

Tampa Bay

The proposed plan amply improved the compactness of the districts that incorporate parts

of Tampa Bay.60 Proposed District 13 is an egg-shaped district surrounding St. Petersburg. The

district is bound on the south, west and east by the borders of Pinellas County. Proposed District

14, shaped somewhat like a tree with a short trunk, is similarly compact and is bound on the west

and north by the boundaries of Hillsborough County, on the south by Tampa Bay, and on the east

by I-75 and the Palm River.

Meanwhile, the current districts swirl in and around the Tampa area. Current District 11

captures much of Tampa proper, wraps around Tampa Bay, and reaches with separate arms into

St. Petersburg and Bradenton. It jaggedly captures parts of Hillsborough County, Pinellas

County and Bradenton County. As a result, instead of preserving the St. Petersburg peninsula

into a naturally compact district, current District 10 has the shape of a lower-case letter “h,” with

two legs straddling District 11 and a neck poking north of the peninsula.

To the north, current District 9 likewise shares a peculiar shape, with many jagged

appendages, reaching down into Hillsborough County and Pinellas County and up into Pasco

County. By contrast, the proposed District 20 captures the remainder of Pinellas County north of

the St. Petersburg peninsula and those parts of Pasco and Hernando County to the west of I-75.

Under the current plan, to the east of Tampa are a northwardly reaching appendage of

District 12 and a southwardly reaching leg of District 9. Each captures parts of the eastern

suburban area of Tampa in Hillsborough County. By contrast, the proposed plan divides the

remainder of Hillsborough County by assigning most of the area east of I-75 to District 21, and

the area west of I-75 and south of District 21 to District 12.

60

Compare Figures 7 and 8 of Appendix.

22

North Florida

The proposed plan also substantially increases the compactness of the northern half of the

state. In the two westernmost districts of the Florida Panhandle, current District 2 has an arm at

the base of the district extending westward for approximately 50 miles across three counties.61

The proposed plan eliminates that appendage.62 Instead, the proposed districts are separated by a

north-south border consisting of the Choctawhatchee River from Holmes County to the

beginning of Bay County and of state road 79 through Bay County.

Similarly, under the current congressional map, the northern half of the state to the east of

the Panhandle is marked by three long, windy districts reaching into Duval County to grab

portions of Jacksonville.63 Current District 4 hugs the northern border, extending from

Tallahassee to Jacksonville. District 4 reaches south into Jacksonville from Nassau County to

capture the fairly affluent and urbanized eastern half of Duval County along the coast of the

Atlantic Ocean. Meanwhile, the approximately 160 miles between Jacksonville and Tallahassee

that District 4 also contains is predominantly rural.

Current District 6 meanwhile extends approximately 150 miles from Jacksonville to

Leesburg, a western exurb of Orlando. Along the way it detours west to grab much of

Gainesville and Ocala. Like District 4, District 6 consists of mostly rural areas. Indeed, even the

portions of Duval County that District 6 grabs are among the more rural parts of Jacksonville.

Jacksonville’s third district, current District 3, as described extensively in Part II.A.2 above,

grabs the black populations from Jacksonville, Gainesville, and Orlando in order to create a

majority black CVAP district.

61




23

With the proposed plan, I sought to improve the cultural compactness of the northern

districts by keeping Northeast Florida together. Slicing Jacksonville into three pieces to

needlessly band parts of Jacksonville with unrelated portions of the state struck me as

unacceptable.64 The rest of the state may perceive Jacksonville as largely indistinguishable from

the western half of North Florida, as Jacksonville shares much of the Southern culture that is

prominent elsewhere in North Florida, but Northeast Florida is in fact quite distinctive from the

rest of North Florida. Jacksonville is considerably more urbanized than the western portion of

North Florida. The city is approximately three times as populous as any other metropolitan area

in North Florida.65 Jacksonville is a major commercial and industrial center; it is home to

multiple Fortune 500 companies and enjoys one of the country’s most dynamic economies.66

Indeed, it is the only city between Tampa and Atlanta that can boast to be the residence of a

professional football team; not even Orlando can say that. The nearest population centers to the

west meanwhile are Tallahassee, which is distinctive for being the state’s capital, and

Gainesville, which is most noteworthy for being the location of the University of Florida. As I

regard Jacksonville as sufficiently district from the western portion of North Florida, I sought to

keep as much of the city together as possible.

64

Any regional bias I may carry may have come into play in my proposals regarding how Florida’s northeastern

districts should look. 65

The population of the Jacksonville metropolitan statistical area is 1,345,596. The population of the Pensacola

metropolitan statistical area is 448,991. The population of the Tallahasee metropolitan statistical area is 367,413.

The population of the Gainesville metropolitan statistical area is 264,275. See U.S. CENSUS BUREAU, 2010 CENSUS

NATIONAL SUMMARY FILE OF REDISTRICTING DATA (2011), available at

http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_NSRD_GCTPL2.US24

PR&prodType=table. 66

See ROBERT D. ADKINSON & PAUL D. GOTTLIEB, PROGRESSIVE POLICY INSTITUTE,

BENCHMARKING ECONOMIC TRANSFORMATION IN THE NATION’S METROPOLITAN AREA 18 (2001) (concluding that

Jacksonville has the 24th-most dynamic economy in the United States), available at

http://www.research.fsu.edu/techtransfer/documents/mnei.pdf.

24

The proposed plan keeps current District 3, now proposed District 26, largely intact.67

District 26 still winds into and around downtown Jacksonville. As a replacement for the two

other districts snaking into Duval County, I created proposed District 24. District 24 consists of

all of Nassau County, much of the Orange Park section of northeast Clay County, and almost the

entire remainder of Duval County that proposed District 26 did not carve out. With the

exception of the highly populous area captured by District 26, containing nearly 300,000

persons, District 24 is otherwise neatly square-shaped, with natural borders on all sides: the

Florida-Georgia border to the north and west, county borders to the south, and the ocean to the

east. Slight deviations occurred at Duval County’s southern borders with St. Johns County and

Clay County in order to achieve population equality. The proposed plan substantially improves

both the geographic and cultural compactness of Jacksonville’s districts.

The proposed plan also amply improves the compactness of the North Florida districts

captured to the west of Jacksonville. The proposed plan contains only one district around

Tallahassee. Doing so allowed for the removal of current District 4’s long, westward arm and

permitted the creation of a clean, north-south border dividing proposed Districts 25 and 22. The

boundary between Districts 22 and 25 extends from the Florida-Georgia border to the Gulf of

Mexico, following county roads through most of Madison and Taylor Counties. District 22, as a

result, became a pleasant circle-shaped district, capturing a lightly-populated rural and coastal

area west of Jacksonville, north of Tampa, and east of Tallahassee. Like District 24, District

22’s otherwise clean shape is disfigured slightly to accommodate District 26’s capture of the

black populations in Gainesville. The most populous areas in District 22 are parts of Orange

Park, a Jacksonville suburb in Clay County; Ocala; and Gainesville.

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25

South Florida

One particular aim of this project was to improve the compactness of the majority-

minority districts. Each of the proposed majority-Hispanic districts accomplishes this without

diminishing the voting power of the Hispanic areas.68 The proposed black districts in South

Florida likewise improve compactness over the current districts.

Proposed District 9, one of the proposed majority-black districts, has substantially

superior compactness to the current majority-black district in Fort Lauderdale and West Palm

Beach. Proposed District 9, as discussed above in Part II.A.2 removes the northernmost and

southernmost appendages of current District 23, thereby cutting the distance between the

northernmost and southernmost black populations by more than half, from approximately 120

miles to 50 miles. Proposed District 9 also removes much of the uninhabited rural land in the

western half of current District 23 in order to keep the Everglades largely contained within a

single, compact district, proposed District 5.

Additionally, containing District 9 as I propose arguably improves the cultural

compactness of the district’s black population. Current District 23 incorporates substantial

populations of blacks just beyond the border of Miami-Dade County, as far north as the more

lightly populated Fort Pierce, and to the west in the rural area in and around Belle Glade. Under

the proposed District 9, the substantial black populations are located in Palm Beach County and

Ft. Lauderdale, a geographically and culturally compact area of South Florida.

The other proposed majority-black district in South Florida has roughly the same

boundaries as the current District 17. I smoothed the edges of the district, but Miami’s black

population is located in a naturally compact area north of downtown Miami and to the west of

US-1, so the shape of proposed District 3 substantially resembles that of current District 17.

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26

From downtown to the north in Miami generally lies a relatively affluent narrow strip of land to

the immediate east of US-1. To the immediate west of US-1 generally lies a poorer section of

the city where a large black population resides. The proposed District 3 follows US-1 exactly as

an eastern border; the current District 17 follows it almost exactly. The western border of

current District 17 is slightly jagged. The proposed District 3 smoothed the western border.

Otherwise, the districts are substantially identical.

The proposed majority Hispanic districts also improve compactness over the current

districts. After constructing proposed District 3, I sought to divide the remainder of Miami’s

population into three regions: (1) downtown Miami and Miami Beach; (2) South Miami; and (3)

the Hialeah, Doral, and Miramar areas to the northwest of Miami-Dade County and southwest of

Broward County. I divided the Hispanic population in proposed District 5 to the north from

proposed Districts 1 and 2 by US-41 to the extent possible. I divided proposed District 2 from

District 1 by US-836 on District 2’s western boundary and state road 992 on District 2’s southern

border. I divided those populations in that manner in order to keep proposed District 2’s

population as compactly centered on downtown Miami as possible. Proposed District 1

meanwhile captures most of the rest of the populous areas of Miami-Dade County and the

portions of North Key Largo north of US-1.

One could argue that proposed District 5, spanning from Broward County to the Florida

Keys lacks compactness by not joining the keys with South Miami, but rather with North Miami

and Southwest Broward County.69 Obviously South Miami is more geographically proximate to

the Keys than the northern portion of Miami is. I chose this districting scheme in order to keep

as much of the Everglades contained within one district as possible and to keep the Everglades in

the same district as the Keys. The alternative would have required that I divide the Everglades or

69


27

separate the Keys from the Everglades, or both. It seemed improper to divide the Everglades

into different districts. It also seemed imprudent to needlessly separate into different districts

Florida’s arguably two most marvelous environmental features. With proposed District 5, I

traded compactness of the district’s two population centers for respect for significant geographic

features and communities of interest.

B. Respect for Political and Geographic Boundaries

As Article III of Florida’s Constitution advises,70 I did not seek to exalt county lines over

otherwise preferable alternative geographic boundaries. Nevertheless, I remained mindful that

county lines may often significantly affect a person’s political and geographic identity, so I

generally sought to follow county lines unless compactness or another interest would appreciably

suffer. For example, the northern border of proposed District 5 follows I-75 in Collier County,

but then jumps to follow the county lines when I-75 enters Broward County.71 Although

following I-75 entirely from Broward County through Collier County would have modestly

improved compactness, I decided to capture the northern half of Broward County because, all

else equal, following county lines struck me as preferable to following a similarly worthwhile

geographic or other political boundary.

In other instances, I decided to follow geographic boundaries over county lines. For

example, the boundary between proposed Districts 27 and 25 follows the Choctawhatchee River

and state road 79.72 If, instead, I had chosen to not divide either Bay County or Holmes County

in the north, the districts would have lost compactness, having a border resembling a step ladder.

Where following a significant geographic boundary like the Choctawhatchee River would allow

70

See Fla. Const. art. III, § 20(c) (“The order in which the standards within subsections 1(a) and (b) of this section

are set forth shall not be read to establish any priority of one standard over the other within that subsection.”). 71



28

me to increase the districts’ compactness, I chose to follow that boundary, as Article III advises.

Similarly, the western boundaries of proposed Districts 18 and 16 follow the St. Johns

River to the river’s end even though doing so meant dividing Putnam County where the river

runs through the county. Deviating from the St. Johns at Putnam County would slightly reduce

the district’s compactness and the border’s simplicity and rationality. Furthermore, I preferred as

a general matter to limit the quantity of boundaries comprising a district’s border when possible.

The St. Johns River served as a highly appropriate district boundary, so deviating from that until

its end seemed imprudent.

Other geographic features to which I attributed particular importance were the St.

Petersburg peninsula, Tampa Bay, the Caloosahatchee River in Fort Myers, the Everglades, the

Florida Keys, Miami Beach, and Key Biscayne. I sought to keep Key Biscayne and Miami

Beach in one district and to avoid gerrymandering Miami Beach.

At other times, I used major roads as district boundaries. I-75 forms the border between

three pairs of districts. I-4, I-95, and US-1 also served as significant boundaries between several

districts.

IV. Conclusion

As is evident from the foregoing discussion, the redistricting process involves tradeoffs

between many competing considerations. There are many rational, apolitical ways to divide

Florida in a manner that complies with the United States Constitution, the Voting Rights Act,

and the Florida Constitution. The plan I propose is only one such scheme, but it is my hope that

the public or the courts may find the plan I propose to be a useful, neutral benchmark against

which to compare whatever redistricting plan the Florida Legislature ultimately adopts.

Appendix

Figure 1: Current District 11

Figure 2: Proposed District 13





Figure 7: Proposed districts in Tampa Bay area

Figure 8: Current districts in Tampa Bay area

Figure 9: Current Districts 1 and 2

Figure 10: Proposed Districts 27 and 25

Figure 11: Current districts between Jacksonville and Orlando

Figure 12: Proposed districts between Jacksonville and Orlando

Figure 13: Current South Florida districts

Figure 14: Proposed South Florida districts

Figure 15: Current Florida Keys and Everglades districts

Figure 16: Proposed Florida Keys and Everglades districts

Documents

Memorandum in Support of Proposed Redistricting Plan of Floridacensusvalidator.blob.core.windows.net... · 2011-05-27 · addition of the black population of St. Petersburg is most