From Ashcroft to Larios: Recent Redistricting Lessons From Georgia

In this Article, we explore the impact of a court-ordered and implemented re-crafting of state legislative districts in the state of Georgia. First, we explore the notion of “fairness” in legislative redistricting and identify the factors associated with a “fair” map. We then describe the partisan nature of the 2001 Georgia state legislative redistricting and the political consequences of this most effective gerrymander. We also describe the two legal challenges to the Georgia maps—Georgia v. Ashcroft and Larios v. Cox—and discuss the path of both cases to the U.S. Supreme Court. We then explore the expected and observed consequences of the Court-ordered and implemented redistricting that undid the unconstitutional Georgia gerrymander, and draw conclusions regarding the prospect for how court remedies can affect partisan bias in redistricting plans

The History of Redistricting in Georgia

In his memoirs, Chief Justice Earl Warren singled outthe redistrictingcases as the most significant decisions ofhis tenure on the Court., A review of the changesredistricting introduced in Georgia supports Warren\u27sassessment. Not only have the obligations to equalizepopulations across districts and to do so in a racially fairmanner transformed the makeup of the state\u27s collegialbodies, Georgia has provided the setting for multiple casesthat have defined the requirements to be met whendesigning districts.Other than the very first adjustments that occurred inthe 1960s, changes in Georgia plans had to secureapproval from the federal government pursuant to theVoting Rights Act. Also, the first four decades of theRedistricting Revolution occurred with a Democraticlegislature and governor in place. Not surprisingly, thepartisansin control of redistrictingsought to protect theirown and as that became difficult they employed moreextreme measures.When in the minority, Republicans had no chance toenact plans on their own. Beginning in the 1980s andpeaking a decade later, Republicans joined forces withblack Democrats to devise alternatives to the proposals ofwhite Democrats. The biracial,bipartisancoalition neverhad sufficient numbers to enact its ideas. After strikingout in the legislature,African-Americans appealed to theU.S. Attorney General alleging that the plans enactedwere less favorable to black interests than alternatives offered by the coalition. Every iteration,save for the plansdrawn in the 1960s and 2011, bore the marks of what theDepartment of Justice (DOJ)believed necessary to secureequal treatment of African-Americans. As will becomeclear in the course of this Article, the DOJ\u27s perspectivehas changed over time.This Article is arrangedchronologically and examineseach of the major rounds of redistricting. Aside fromadjusting for population shifts, which remain constant, adifferent concern or theme dominated each round. In the1960s, Georgia and other states were like individuals whohad begun flexing long-ignored muscles as they set aboutadjusting lines that had gone unchanged for decades. Inthe 1970s, as the need for redistricting merged withdemands from the Voting Rights Act, pushback occurredas it did in the many other aspects of racial interactionasthe nation finally began to take seriously its commitmentto equality. A decade later, Georgia encountered a DOJthat had precise quantitative goals for what wasnecessary to provide African-Americans an opportunity toelect their preferences. In the 1990s, DOJ incorporatedSection 2 of the Voting Rights Act into its preclearancereviews and demanded that Georgia enhance the numberof majority-black districts and that it maximize the blackpercentage in those districts. The turn of the new centuryfound the generations-longDemocratic control of Georgiaslipping away and the majority party pulled out all thestops desperately trying to cling to power. Democraticefforts could not withstand the tide of partisanrealignment and court challenges so that in 2011Republicans sat at the computer terminals andredistrictedGeorgia. Republicans attempted to maximizetheir control over the legislature by devising plans thatmight produce super-majorities with two-thirds of theseats in each chambe

4-H Volunteer Continuing Education Academy

The 4-H Volunteer Continuing Education Academy was developed to provide 4-H club leaders a continuing education opportunity, to assist them in developing and enhancing the skills and knowledge necessary for their volunteer role, and to provide a means for 4-H livestock and horse club leaders to recertify. All participants reported satisfaction with the academy and indicated that they would attend again and would recruit other volunteers to participate. The academy can be replicated in many ways and introduced at any level to provide continuing education and volunteer support. This article describes the academy and provides information for those who may wish to implement a similar program

State and local agencies are more effective than the federal government in housing discrimination enforcement

Discrimination by those selling or renting homes is illegal under the 1968 Fair Housing Act (known as Title VIII), but housing discrimination and segregation in the US have not been eliminated. Federal, state, and local agencies are responsible for enforcing Title VIII, so in which part of government is enforcement most effective? In new research which analyses data from the ..

Race, Ethnicity, and Fair Housing Enforcement: A Regional Analysis

This article systematically compares how federal, state, and local civil rights agencies in the ten standard regions of the United States enforce fair housing law complaints filed by Blacks and Latinos. Specifically, it explores the extent to which regional outcomes at all three levels of government are decided favorably where, between 1989 and 2010, a racial or ethnic violation of the Fair Housing Act of 1968 or the Fair Housing Amendments Act of 1988 is alleged. The results reveal significant variations in outcomes between these groups across the country. Most importantly, the probability of an outcome favorable to the complainant depends on the region in which the complaint is filed, the race or ethnicity of the complainant, and the racial or ethnic composition and the number of complaints filed per capita in the state in which a complaint originates. In general, while complaints filed by Latinos are more likely to receive a favorable outcome than those filed by Blacks, favorability rates for Latinos are more dependent on the region where the complaint is processed than they are for Blacks

A Practical, Ethical Critique of Hydraulic Fracturing and the Shale Gas Extraction Process

This thesis analyzes the emerging technology of hydraulic fracturing and shale gas extraction process through a pluralistic philosophical approach. Rather than defending traditional values in nature, such as intrinsic value, I defend a metaphilosophical pragmatism centered on policy implications. I argue that different philosophical positions will, most of the time, converge on similar policy recommendations, although appealing to different justifications for why that policy ought to be adopted. After defending why I avoid past dogmas in environmental ethics, I create my pluralistic approach by first cultivating an attitude of humility toward the precious resource of water. Then, I argue companies should not be allowed to classify their slick water mixture as a proprietary formula protected by the "trade secret" clause because this violates the notion of informed consent of the residents. Next, I examine exemptions from the Safe Drinking Water Act and how the structure of the law perpetuates the use of fossil fuels throughout modern society. Finally, I examine the discourse about fugitive methane emissions and whether natural gas is the "bridge-fuel" to the future as proponents claim. I conclude this thesis defending natural gas as a viable option to satisfy current high-energy demands rather than coal or oil, but I acknowledge that since natural gas is another fossil fuel, that a switch to renewable energy should occur as soon as possible

Sequestration of Martian CO2 by mineral carbonation

Carbonation is the water-mediated replacement of silicate minerals, such as olivine, by carbonate, and is commonplace in the Earth’s crust. This reaction can remove significant quantities of CO2 from the atmosphere and store it over geological timescales. Here we present the first direct evidence for CO2 sequestration and storage on Mars by mineral carbonation. Electron beam imaging and analysis show that olivine and a plagioclase feldspar-rich mesostasis in the Lafayette meteorite have been replaced by carbonate. The susceptibility of olivine to replacement was enhanced by the presence of smectite veins along which CO2-rich fluids gained access to grain interiors. Lafayette was partially carbonated during the Amazonian, when liquid water was available intermittently and atmospheric CO2 concentrations were close to their present-day values. Earlier in Mars’ history, when the planet had a much thicker atmosphere and an active hydrosphere, carbonation is likely to have been an effective mechanism for sequestration of CO2