I was reading about Shaw v. Reno, a case about a congressional district that was altered on the basis of the race of its voters.

Is there a law (precedent or statutory) which requires congressional districts to be contiguous? I was thinking that you could gerrymander much more effectively if you could make up a district from multiple unconnected parts.

The oddly shaped district in question:

NC's twelfth district

1 Answer 1


No; only 23 states require their congressional districts to be contiguous.

See Reapportionment and Redistricting in the West by Gary F. Moncrief:

Only 23 states have [contiguity] requirements for their congressional districts, although as a practical matter most congressional districts will be contiguous; the relative dearth of legal limits is a manifestation of the fact that few states have provided any express legal constraints on congressional districting at all.

But that's not to say more states don't have contiguous districts. On Profesor Justin Levitt's website, he observes that:

Many states require contiguity only "to the extent possible," and courts generally accept anomalies that otherwise seem reasonable in context.

I am having a difficult time finding a list of states with such requirements; I will update if I find it.

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