| Abstract: | 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. |
