The Third Criterion: Compactness as a Procedural Safeguard Against Partisan Gerrymandering

@article{Polsby1991TheTC,
  title={The Third Criterion: Compactness as a Procedural Safeguard Against Partisan Gerrymandering},
  author={Daniel D. Polsby and Robert D. Popper},
  journal={Yale Law \& Policy Review},
  year={1991},
  volume={9},
  pages={6}
}
This paper addresses partisan gerrymandering and proposes a formal remedy. In addition to adhering to criteria which mandate that representational districts be composed of contiguous territories and have equal populations, we suggest that those who define district boundaries must also be required to respect a third criterion, the constraint of compactness. 

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Engstrom , The Supreme Court and Equipopulous Gerrymandering : A Remaining Obstacle in the Questfor Fair and Effective Representation , 1976 ARIZ
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Although this is one of the best of the compactness measures, for unknown reasons Colorado's judges have chosen to ignore it in favor of the contrived standard of Acker v. Love; see
    Another constitutionally permissible goal of legislative districting, see
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