Abstract
In 1986, the United States Supreme Court held that a political gerrymandering case was justiciable under the equal protection clause of the United States Constitution. There was, however, no majority opinion on “a judicially manageable standard to determine whether a redistricting plan was a product of unconstitutional gerrymander. For more than two decades, the Supreme Court hasn’t found the reliable standard yet. In this note article, I briefly outline the relationship of gerrymandering claims and “one person, one vote” principle which is used mainly in malapportionment cases. After describing the deadlocked development of political gerrymandering case law, I introduce some attempts to regulate a political gerrymandering, using procedural law for redistricting and independent redistricting commissions. Those methods are based on a state constitution rather than federal one, and can be understood in terms of judicial federalism.
