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Congressional Apportionment: The Unproductive Search For Standards And Remedies, Michigan Law Review

Michigan Law Review

The increasingly complex problems of elucidating congressional apportionment standards and granting appropriate relief when voting rights have been materially diluted were again brought to the fore in the recent districting decision of Calkins v. Hare. This federal district court decision is illustrative of the uncertainty caused by the Supreme Court's opinion in the landmark case of Wesberry v. Sanders. Although Wesberry resolved two previously contested issues by ruling that congressional apportionment disputes are susceptible of judicial determination and by setting a standard of population equality in delimiting districts, two associated questions were left unanswered. First, even though Wesberry …