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The frequency of recent reapportionment decisions has increased public concern for voting equality.'As legislative districts become more equally populated within a state through legislative and judicial action, attention will likely turn to combating the gerrymander.? Antigerrymandering prohibitions have been on the books, at both federal 3 and state 4 levels, for well over a century; but enforcement has generally been lax or nonexistent.5 A bill introduced in the 89th Congress attempting to curtail use of the
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