Repairing the Crack in New Orleans' Black Vote: VRA's Results Test Nullifies "Gerryduck"

In 1982, Section 2 of the U.S. Voting Rights Act was amendedto allow plaintiffs to prevail in voting rights litigation ifthey demonstrate that a challenged law or practice has a discriminatoryresult. One of the first applications of this new statutoryprovision invalidated a congressional districting plan for theNew Orleans metropolitan area, a plan that had divided the city'sblack population virtually in half. This article reviews boththe making and the unmaking of that plan, derisively known asthe "gerryduck." Although the judicial action invalidating thisexercise in racial cartography demonstrates the potential importanceof this new section of the VRA as a legal weapon against minorityvote dilution, the results test provides federal judges withenormous discretion, and the application of the test may thereforebe quite capricious.     

Consumer-sponsored prepaid group practice: restructuring the health care system

The traditional separation of health care delivery and financing systems is breaking down as various new types of health care facilities are established and as payment continues to be a major concern. Group Health Cooperative of Puget Sound (GHC) was organized as a prepaid group practice system responsive to consumers. Costs, methods of payment and delivery of care are interrelated and are all influenced by consumer ownership. GHC has been refining its benefit programs since 1945. Strategies for controlling use and costs focus on improved provider management and on flexibility. This article explains how the structure of GHC benefits the consumer.