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so narrowly drawn that she had voted to reject it. 462 U.S. at 850. The Court reaffirmed this narrow <br />view of its holding in Brown by later citing it as authority for the statement that “no case <br />indicated that a deviation of some 78% could ever be justified.”Board of Estimate v. Morris, 489 <br />U.S. 688, 702 (1989). <br />In Voinovich v. Quilter,507 U.S. 146 (1993), the Supreme Court reversed a decision of the <br />federal district court striking down Ohio’s legislative plan bec <br />plan was 13.81 percent and the overall range of the Senate plan <br />pointed out that preserving the boundaries of political subdivis <br />might justify an overall range in excess of ten percent. <br />There may not be any other “rational state policies” that will j <br />the ten-percent standard. But with the multitude of plans that <br />your consideration, you may wish to adopt other policies to gove <br />percent overall range. <br />Courts that are called upon to draw redistricting plans, when le <br />adopted policies for the parties to follow in submitting propose <br />are not required by the federal constitution, and have not been <br />percent standard, but they have helped the three-judge courts to <br />were fair in adopting their plans. These policies often have in <br />districts must be composed of contiguous territory; Carstens v. Lamm, 543 F. Supp. 68, 87­ <br />! <br />88 (D. Colo. 1982); Shayer v. Kirkpatrick, 541 F. Supp. 922, 931 (W.D. Mo. 1982) aff’d sub <br />nom.Schatzle v. Kirkpatrick, 456 U.S. 966 (1982); LaComb v. Growe, 541 F. Supp. 145, 148 <br />(D. Minn. 1982); <br />districts must be compact; e.g.,Carstens v. Lamm, 543 F. Supp. at 87-88; Shayer v. <br />! <br />Kirkpatrick, 541 F. Supp. at 931; LaComb v. Growe,supra;South Carolina State Conference <br />of Branches of the National Association for the Advancement of Colored People v. Riley, 533 <br />F. Supp. 1178, 1181 (D. S.C. 1982); Dunnell v. Austin, 344 F. Supp. 210 (E.D. Mich. 1972); <br />David v. Cahill, 342 F. Supp. 463 (D. N.J. 1972); Preisler v. Secretary of State, 341 F. Supp. <br />1158 (W.D. Mo. 1972); Skolnick v. State Electoral Board, 336 F. Supp. 839, 843 (N.D. Ill. <br />1971); Citizens Committee for Fair Congressional Redistricting, Inc. v. Tawes, 253 F. Supp. <br />731, 734 (D. Md. 1966) aff’d mem. sub nom. Alton v. Tawes,384 U.S. 315 (1966); and <br />districts should attempt to preserve communities of interest; e.g.,Carstens v. Lamm, 543 F. <br />! <br />Supp. at 91-93; Shayer v. Kirkpatrick, 541 F. Supp. at 934; LaComb v. Growe,supra;Riley, <br />533 F. Supp. at 1181; Dunnell v. Austin, 344 F. Supp. at 216; Tawes, 253 F. Supp. at 735; <br />Skolnick, 336 F. Supp. at 845-46. <br />As of 1983, the constitutions of 27 states required districts to <br />territory, and the constitutions of 21 states required that dist Karcher v. Daggett, <br />462 U.S. 725, 756 n. 18 (1983) (Stevens, J., concurring). <br />16 <br /> <br />