The Death of Gerrymandering: Congress Can and Should Eliminate All Congressional Districts and Create New Districts Based Upon Existing County Boundaries in the States

I. Introduction

The contours and nature of Congressional districts for the election of members to the House of Representatives (House) — particularly who creates them and how they are distorted for political advantage — has been the subject of heated debate since the founding of our nation. (Griffith, E.C. 1907). (Vieth v. Jubelirer 2004). The partisan changes that include, exclude or fragment certain populations — now commonly known as “gerrymandering” — has been a significant contributor to the burgeoning polarization problem in the U.S. political system.[1] (Altman, M. and McDonald, M. 2015). (Engstrom, E.J. 2013). Both ideological and “affective” polarization have stymied legislative progress. (Iyengar S., et al. 2019). As such, Congress repeatedly fails to enact fair and balanced legislation to address the nation’s most significant problems. (Griffin, P. and Andres, G. 2022).

In 2019, the Supreme Court terminated federal judicial review of alleged partisan-motivated gerrymandered maps. (Rucho v. Common Cause 2019).[2] The court applied the “political question” doctrine in ruling that federal courts cannot and should not render decisions that are essentially political. Thus, the partisan districting process will continue unabated unless legislators in the States or Congress terminate the existence of districts altogether or provide for an alternative manner for the creation and modification of district boundaries. Therefore, unless and until there is such action, partisan gerrymandering — and its attendant problems — is here to stay.

This paper proposes a new method for creating congressional districts for House seats, with a view toward reducing polarization. The County Plan (as I have termed it) would replace all existing congressional districts with a new system that uses existing county boundaries in the States. The goal of the County Plan (Plan) is to incentivize congressional candidates and elected Members of the House, in some of the new districts that will have a more balanced mix of Democrats and Republicans, to moderate their positions and actions because they will no longer be representing politically homogeneous constituencies. The result could be an important first step in reducing legislative gridlock stemming from ideological and affective polarization.

Section II, below, provides historical context in terms of how the current system was legislatively created and how it has evolved. In Section III, there is a discussion regarding scholarly opinions as to how current districting and redistricting contributes to polarization. Section IV reviews reforms that have been the subject of discussion in scholarly literature and political circles. In Section V, the County Plan is proposed and explained. In the Conclusion, there are suggestions concerning further research that may shed light on the viability and desirability of the Plan.[3]

II. Historical Context

Congress first exercised its Elections Clause[4] power in 1842, requiring the existence of House electoral districts. It subsequently modified the nature and characteristics of these districts several times, over a 90-year period. In 2019, the Supreme Court of the United States explicitly validated the power of Congress take such actions. (Rucho v. Common Cause 2019). Therefore, the reform plan proposed in this paper is constitutionally sound. Indeed, the court mentioned that Congress could — as is proposed in this paper — use existing “political subdivisions” as a basis for district creation.

Elmer C. Griffith, an early scholar of the practice of manipulating voting districts for electoral advantage, traced the practice back to the Colonial Era, as early as 1702. (Griffith, E.C. 1907). Professor Erik Engstrom also noted that the practice had its roots in the colonial legislatures. (Engstrom, E.J. 2013). He described the partisan battles that were pervasive during the early days of the republic — from 1790 to 1840 — and the incessant partisan wrangling for electoral advantage.

When Governor Gerry of Massachusetts approved a remap of Massachusetts in 1812 that was particularly egregious in terms of its partisan redistricting, politicians subsequently coined the phrase “Gerrymandering” to succinctly characterize the process (one of the districts resembled the shape of a salamander) (Engstrom, E.J. 2013). Thereafter, and until today, gerrymandering has persisted as a mainstay in American politics. (Calabrese, S. 2007).

The creation of congressional electoral districts was originally conducted by state legislatures, but they were not mandated prior to enactment of Section 2 the Apportionment Act of 1842 (Act). (Quitt, M.H. 2008). Indeed, several states held “at-large” elections whereby all candidates ran statewide. (Engstrom, E.J., 2013). (Lublin, D. 2019). The variance in electoral methods among the States was permissible because the Constitution deferred to the discretion of the States on this question, subject to action by Congress to intervene and override state processes.

Article I Section 2 of the U.S. Constitution delineates a process for determining the number of representatives to serve in the House, and their apportionment among the States. (U.S. Const. Art I, Sec. 2). However, Section 2 does not address how they would be elected. The only provision as to the method of election is contained in Article I, Section 4 of the U.S. Constitution (Elections Clause). That clause is silent on the question of the existence of election districts in the House. It provides:

The times, places and manner of holding elections for Senators andRepresentatives, shall be prescribed in each state by the legislature thereof;but the Congress may at any time by law make or alter such regulations,except as to the places of choosing Senators.

(U.S. Const. Art I, Sec. 4). Prior to 1842, Congress did not “make or alter” any law to determine the “manner of holding [congressional] elections,” and the States remained free to either create districts or hold statewide contests. (Colegrove v. Green 1942).

Since the practice of creating districts to gain political advantage was occurring prior to the ratification of the Constitution, the Founders were aware of the problems associated with the practice. They decided to permit the status quo to remain, in the absence of federal legislation that would “check and balance” the power of the States in this regard. (Rucho v. Common Cause 2019).

In Federalist №59, Alexander Hamilton wrote:

“. . . it will … not be denied that a discretionary power over elections ought to exist somewhere. It will, I presume, be as readily conceded that there were only three ways in which this power could have been reasonably modified and disposed: that it must either have been lodged wholly in the national legislature, or wholly in the State legislatures, or primarily in the latter, and ultimately in the former.”[5]

Hamilton’s view, as embodied in Article I, Section 4, was subsequently fully ratified by the States.

Upon its passage, the States were thus mandated, for the first time in U.S. history, to carve up their states into contiguous electoral territories. (Engstrom E.J. 2019). Section 2 of the Act states:

That in every case where a State is entitled to more than one Representative,the number to which each State shall be entitled under this apportionmentshall be elected by districts composed of contiguous territory equal in numberto the number of Representatives to which said State may be entitled, noone district electing more than one Representative.

(Apportionment Act of 1842). This provision remained the law until Congress took further action in subsequent reapportionment acts in 1872, 1882, 1891, 1901, 1911 and 1929 (Wood v. Broom 1932) and in 1962, as discussed below.

Thirty years after the 1842 Act, Congress added the requirement that districts have equality as to the number of inhabitants in each district (as equally as practicable). (Engstrom, E.J. 2013). Twenty-nine years thereafter, in the Reapportionment Act of 1901, Congress added the requirement that districts be “compact.” In 1911, Congress renewed all three criteria of contiguity, compactness and equality of population (Rucho v. Common Cause 2019). However, in the Reapportionment Act of 1929, the legislation was silent as to these three requirements, leaving the question as to whether the matter of district configuration, as contained in the 1911 Act, had lapsed.

Noting the absence of the three requirements in the 1929 Act, the Supreme Court held that they were implicitly repealed (Wood v. Broom 1932). The court reviewed the legislative history regarding the 1929 Act and found that the initial bills considered in the first and second sessions of the 70th Congress did indeed contain the requirements of contiguity, compactness and equality of population. However, a subsequent bill was introduced with these requirements omitted, and that version passed. Thus, it was the “manifest intention of Congress” to leave districting and redistricting completely subject to the discretion of the States (Wood v. Broom 1932).

In 1962, Congress passed the Uniform Congressional District Act, requiring single member districts. (2 U.S.C. §2c 1962). After the passage of this Act, no further changes have been made by Congress.

Between 1932 and 2019, there was a plethora of litigation regarding maps that were allegedly drawn for partisan purposes, with plaintiffs arguing that the districts should be stricken by the federal courts. Forty-Five such cases reached the Supreme Court, but the court refused to strike any of the districts that were the subject of the litigation before it. (Rucho v. Common Cause 2019).

In Rucho, the Supreme Court held that federal courts do not have jurisdiction[6] to entertain such cases, i.e., those challenging district configurations allegedly based upon partisan motives. The court struggled to find a standard of review that would allow federal courts to evaluate and potentially strike a map without injecting the court’s political view as to what is “partisan” or “too partisan” (Rucho v. Common Cause 2019). The court reviewed its prior decisions and noted that it had always struggled with the difficulties of court supervised partisan gerrymandering.

Accordingly, after Rucho, any legal challenges to maps based upon alleged partisan gerrymandering can only be brought in courts of each State, in the context of whether there has been compliance with the state’s districting scheme.

III. The Existing System is a Contributor to Polarization

Much ink has been spilled regarding the growing polarization among members of Congress and the political elites in the U.S. (Layman, et al. 2006). Indeed, “[a] growing body of empirical research shows that the parties in government, particularly those in Congress, are each growing more homogeneous in their policy positions, while the differences between the two parties’ stands on major policy issues are expanding.” (Layman, et al. 2006). Changes have been observed on economic issues such as income taxes and social welfare programs and cultural issues such as civil rights, racial equality, abortion, LGBTQ rights, school prayer and religious views (traditionalist, modern or secular). (Layman, et al. 2006).

The three main gerrymandering techniques are known as “cracking,” “packing” and “stacking.” Cracking entails dividing a group among multiple districts so that their votes are outweighed in all districts. Packing gerrymanders place as many members of a group as feasible into a single district to reduce its influence in other districts. “As opposed to cracking or packing, stacking relies on multimember districts to undercut the influence of the targeted group.” (Lublin, D. 2019). These methods indeed invite partisan boundaries motivated by race, ethnicity and party affiliation.

Some scholars attribute realignment in the white South (Jacobson 2000) or characteristics of the mass coalitions of citizens (Fiorina and Abrams, 2008) as contributors to polarization. Others, however, have focused on increasing discrepancies — via gerrymandering — between typically Democratic and Republican House electoral districts as a contributor. (Altman, M. and McDonald, M. 2015). (Engstrom, E.J. 2013).

In 2009, professors McCarty, Poole and Rosenthal challenged what they characterized as:

A narrative [that] is attractive not only because of analytical elegance, butalso because it suggests a single, perhaps even feasible, solution to whatails the American polity: take the politics out of redistricting. Districtsdrawn by neutral experts and judges would be heterogeneous and politicallymoderate. Appealing to independents would become the key to winningelection, and polarization would become a thing of the past. Unfortunately,although elegant in description and prescription, the story may not be true.

(McCarty, et al., 2009). They cite a lack of empirical support for the conclusion that gerrymandering creates or exacerbates polarization. There are faults, I believe, in both their logic and methodology that led them to their conclusion that “gerrymandering has not contributed to polarization in the House.”

McCarty and his colleagues first argued that the Senate has also experienced an increase in polarization at the same time as the House, suggesting that since senators run state-wide, districting may not be at play here. After making that general observation, they sought to quantify the amount of polarization in each chamber. They produced a chart (reproduced as Figure 1, below) that supports the opposite conclusion of their thesis because the data show that polarization in the House had increased at a greater rate and became more significant after the redistricting in 1990.

In seeking to dispute the findings shown in Figure 1, they argue that there are several problems in seeking to compare polarization across the two chambers.[7] With regard to the timeframe, they argue that the gap “appears” to close after 2002. Notably, however, their article was published in 2009, and in the 14 years hence, further increases in polarization in the House have been observed by other scholars. These other scholars have also chronicled the opinions of many other political scientists who reach the conclusion that indeed gerrymandering has contributed to polarization in the House. (Engstrom, E.J. 2013). (Altman, M. and McDonald, M. 2015).

In furtherance of their hypotheses, McCarty and his colleagues referenced various measures used by scholars to characterize what polarization is, such as “extreme voting records” or measuring competitiveness in relatively homogeneous districts by presidential vote share. There seem to be difficulties, in my view, in placing a numerical value as to how extreme a member’s voting record may be. Bills that are voted on are complex, and there are many motivations for different types of votes at different times, and on different issues and pieces of legislation.

Finally, McCarty and his colleagues ran a computer simulation using counties[8] to argue that gerrymandering does not contribute to polarization. However, their method has been sharply critiqued as illogical and that it may indeed support the opposite conclusion. (Altman, M. and McDonald, M. 2015). Notably, the county method they employed subdivided large counties into “1,000 person blocks” and they assumed that each block was identical in terms of their political composition to the county. Altman and McDonald find the simulation, and the conclusions drawn by McCarty and his colleagues, as an “odd” data assumption.

The predominant view, however, among scholars and political scientists — as admitted by McCarty and his colleagues — is indeed that gerrymandering is a contributing factor to polarization. (Engstrom, E.J. 2013). (Altman, M. and McDonald, M. 2015). In their book chapter entitled “Redistricting and Polarization,” Altman and McDonald performed an extensive literature review, noting and analyzing the conclusions of numerous prominent scholars that ideological polarization is negatively affected by redistricting due to the election of more ideologically extreme candidates from districts that are drawn to achieve these results.

They first note that:

. . . the causal chain between redistricting and elite polarization has twonecessary conditions. First, the ideological character of the districts’constituencies must be related to the ideological character of theirelected representatives. Second, redistricting must be able to affectdistricts’ ideologies.

(Altman, M. and McDonald, M. 2015). After reviewing several aspects of these conditions and their extensive data analysis and review of the literature published by other scholars, they conclude that redistricting is a contributor to polarization.

A key factor in the analysis by Altman and McDonald (and other scholars)[9] is the reduction in the number of competitive districts that exist after redistricting. Competitive districts tend to produce more moderate politicians and, conversely, if the overall number of competitive districts is continuously declining, there will be a concomitant increase — at the very least — of the number of House members with opposing ideological viewpoints. Indeed, they state that a reduction in the “the number of competitive districts that, through the connection of district partisanship and members’ ideologies, drive elite polarization.” They succinctly conclude: “The preponderance of the evidence shows redistricting results in fewer competitive districts in the past three decades.”

In Figure 3, Altman and McDonald map the decline in competitive districts over time, after redistricting.

However, Altman and McDonald provide a commonsense caveat: “redistricting cannot be responsible for all elite polarization. Scholars find that redistricting makes a contribution.” However, they find that the problem is significant enough that reform is necessary because it has a likelihood of reducing polarization.

Professor Engstrom, in reviewing the literature as to the potential reduction in competitive districts from gerrymandering notes that:

Indeed, identifying the connection, if any, between gerrymandering andelectoral competition has been one of the front-burner questionsoccupying students of congressional elections for the past 30 years.

* * * *

Political science research, however, is far from reaching a consensus onwhether redistricting can serve as a plausible explanation for decliningrates of competition in House elections.

(Engstrom, E.J. 2013). His critique of political scientists who say that there is not a decline in competition is that they have not examined the long arc of history, as he has done in the work that formed the basis for his book. He conducted a fascinating analysis that leads to the conclusion that gerrymandering techniques do indeed mater in terms of the reduction of competition.

Professor Engstrom compared the redistricting plans in Ohio in 1882 and 2002 as a proxy for extrapolating the likely effects upon competition from gerrymandering. The conditions for these two years in Ohio, in terms of the political landscape (republican control of the districting process) and the political climate were similar. He found that the reduction in competition in 1882, using a quite different gerrymandering technique than we see today, was significantly less than in 2002. He thus concludes:

These results, albeit for one state, suggest that the debate over redistrictingand electoral competition needs to be reframed. In considering this debate,one needs to ask not just what marginal changes redistricting produces, butwhat would redistricting look like if we returned to 19th-century standards.Looking at redistricting from the latter perspective strongly suggests thatdistrict design does indeed influence modern electoral competition. But it isonly by turning to the past and expanding our knowledge of redistrictingthat this insight emerges.

(Engstrom, E.J. 2013).

IV. Potential Solutions: Independent Commissions and Computer Generated Maps

Many reforms to the districting process have been discussed in the literature, the most prominent of which is the creation of non-partisan commissions that would draw district maps. The goal is to produce nonpartisan maps will foster more competitive elections, resulting in the election of less polarized legislators. (Engstrom, E.J. 2013). Some states have decided to hand the process over to independent citizen-based commissions. For example, California, viareferendum, chose to create a citizen-based redistricting commission that will draw both state legislative and U.S. House district maps. (Cal. Const. Art. XXI. Cal. Gov’t Code §§ 8251–8253).

Several observational studies observe that reform via the use of independent/non-partisan commissions will not result in a greater number of competitive districts. (Abramowitz et al. 2006). (Ryan and Lyons 2014). However, Altman and McDonald noted that these studies do not consider the fact that most of the enabling legislation that authorizes such commissions do not require the drawing of non-partisan districts. (Altman and McDonald, 2015). They also provide other significant retorts to those who have promoted the value of such commissions. They wrote:

A general problem with these analyses is that they do not deeply consider thecausal mechanisms linking redistricting commissions’ rules and membership tomore competitive districts or moderation of elite polarization. Only twostates, Arizona and Washington, explicitly have a redistricting criterion todraw competitive districts (McDonald 2007). California’s commission is notrequired to draw competitive districts, so the theory is underdeveloped as to whythe state’s newly enacted citizen commission would reduce polarization.Likewise, Abramowitz et al. (2006) and Ryan and Lyons (2014) paint allcommissions with a broad brush. We are not surprised that commissions areindistinguishable from legislatures if classification of commissions includespredominantly partisan or bipartisan commissions that may be politicallymotivated to draw partisan or bipartisan gerrymanders, both that theoreticallyshould result in no uncompetitive districts

(Owen and Grofman 1988).

The independent commission solution was proposed by the Democratic party and voted upon in the House as part of a large reform measure dubbed “H.R. 1.” (H.R. 1, 116th Cong., 1st Sess., §§ 2401, 2411. 2019). The measure passed the House but died in the Senate.

The bill provides for the creation of 15-member commissions in each state comprised of five Democrats, five Republicans and five independents (“not affiliated with either of the political parties”). Notably, the bill does not provide for the drawing of non-partisan or competitive districts. There is a complex set of criteria in the bill, in Section 2403(a). It provides:

SEC. 2403. CRITERIA FOR REDISTRICTING.

(a) Criteria — Under the redistricting plan of a State, there shall be established single-member congressional districts using the following criteria as set forth in the following order of priority:

(1) Districts shall comply with the United States Constitution, including the requirement that they equalize total population.

(2) Districts shall comply with the Voting Rights Act of 1965 (52 U.S.C. 10301 et seq.), including by creating any districts where two or more politically cohesive groups protected by such Act are able to elect representatives of choice in coalition with one another, and all applicable Federal laws.

(3) Districts shall be drawn, to the extent that the totality of the circumstances warrant, to ensure the practical ability of a group protected under the Voting Rights Act of 1965 (52 U.S.C. 10301 et seq.) to participate in the political process and to nominate candidates and to elect representatives of choice is not diluted or diminished, regardless of whether or not such protected group constitutes a majority of a district’s citizen voting age population.

(4) Districts shall respect communities of interest, neighborhoods, and political subdivisions to the extent practicable and after compliance with the requirements of paragraphs (1) through (3). A community of interest is defined as an area with recognized similarities of interests, including but not limited to ethnic, racial, economic, tribal, social, cultural, geographic or historic identities. The term communities of interest may, in certain circumstances, include political subdivisions such as counties, municipalities, tribal lands and reservations, or school districts, but shall not include common relationships with political parties or political candidates.

Quite frankly, this provision is an elections lawyer’s dream. In my view, there are so many issues that can be litigated here — virtually endlessly. The result will be a lack of trust, lack of respect for the process and politicization claims based upon the necessity that the Department of Justice review the maps for compliance with the criteria noted above [H.R. 1, SEC. 2413(c)(5)].

Computer generated models have also been considered as a method for district creation. Altman and McDonald conducted an extensive review of these suggested computer-generated methods and concluded that the scholarly opinions and simulations that have been run to date do not reveal a consensus as to whether such methods would result in the creation of competitive districts. They also noted that, based upon the current evidence, they can only “conjecture” that the effects of such commissions will be neutral or positive, “but . . . that these effects have yet to be systematically measured in the literature.”

Accordingly, after critiquing the commission solution and computer-generated district creation method, Altman and McDonald do not suggest a method by which the polarization reduction aims can be realized. Thus, we now turn to the solution proposed here: The County Plan.

V. The County Plan

For the County Plan, the states would simply divide the population of their state by the number of representatives in the state. The result would be a specific number of citizens per representative. In some instances, in less populous regions of a state, blocks of counties would become districts. But in more populous counties, House candidates would run county wide.

Of course, in counties where the population is still homogeneous in terms of ideology, moderate candidates would not emerge. But in some of the new districts, voters would be more heterogeneous in terms of ideology, race and socioeconomic status, resulting in the election of more moderate candidates.

For example, there are 26 Representatives in the House from the State of New York.[10] The population of New York State is 19,677,000.[11] Thus, each representative in the state would represent 756,807 people. The population of New York County (Manhattan) is 1,577,000.[12] Thus, there would be two at-large candidates in that county. These candidates would need to seek votes from wealthy Wall Street residents, those facing extreme economic challenges and everyone in between. The candidates would also need to appeal to voters of all races and those with competing political ideologies. For example, the county is 18.5% Black or African American, 26.4% Hispanic and 13% Asian. Regarding income, 17.4% are in poverty.

The current district map of New York County, as shown below, however, has three districts: a midtown district — Dist. 12, an uptown district — Dist. 13 and the lower portion of the county is gerrymandered to be lumped together with a portion of Brooklyn, i.e., Dist. 10.

A quick review demonstrates the significance of using the County Plan versus the existing maps. The populations of Districts 12 and 13 are each quite different from the county overall. For example, District 12 is only 5% Black and African American as opposed to 18.5% for the entire county. District 13 is 55% Hispanic versus 26.4% for the entire county.[13] Merging Districts 12, 13 and a portion of District 10 — the entire county — would yield a quite different and more diverse electorate.

VI. Conclusion

Obviously, there is no one magic bullet here. There is no proposed reform to the current districting and redistricting process that claims to be a panacea in terms of “curing” the polarization conundrum. Of course, not all districts, likely not even a majority, can be made competitive. Reform to this process is but one piece of the puzzle in terms of the quest to alleviate the problems caused by polarization in the House.

Further research is needed to perform calculations to determine whether there would be a number of districts that are more likely to be competitive, likely resulting in the election of more moderate members of the House of Representatives. It is also suggested that research be performed to determine whether the new method would be somewhat neutral, meaning that the result would not create more ideologically lopsided districts than we currently have. The hope is that there would be an increase in competitive districts but not the creation of additional highly partisan districts. This analysis would be important to determine the political viability of this proposal because a coalition of members in Congress would be needed to implement such a reform, especially in the Senate, which has the filibuster as a weapon to block even popular legislation.

If the result is relatively neutral in terms creating more competitive districts and not more highly partisan districts, it would be easier to pass the measure and increase the chances that it would remain in effect and not be repealed by a subsequent highly partisan Congress.

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Competition in U.S. House Elections.” The Journal of Politics 68 (1): 75–88.

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(2015). American Gridlock: The Sources, Character and Impact of Political Polarization. Cambridge

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Congressional Districts.” Public Choice. 130:23–40.

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125, 139 to 143).

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Virginia’s 1788 Congressional Districting.” Early American Studies, 9(3):781–820.

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Characteristics, Causes, and Consequences.” Annual Review of Political Science. 9: 83–110.

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[1] Three professors have published an article disagreeing that there is a causal link between partisan districting and polarization. (McCarty, N., Poole, K.T. and Rosenthal, H, 2009). The varying opinions as to causation, of which there are many, will be addressed in Section III of this paper.

[2] The Supreme Court will continue to address alleged racially motivated gerrymandering under the anti-discrimination provision (“Equal Protection Clause”) of the 14th Amendment to the U.S. Constitution and one-person-one vote challenges to district configuration.

[3] This paper does not address the numerical apportionment and reapportionment of House Members between and among the States based upon updated U.S. Census bureau data, every 10 years. Rather, the focus here is solely upon repeal and replacement of Section 2 of the 1842 Act that created congressional districts in the first instance.

[4] Article I, Section 4 of the U.S. Constitution is commonly referred to as the Elections Clause.

[5] https://avalon.law.yale.edu/18th_century/fed59.asp. Hamilton’s use of the past tense was because he was writing, after the Convention, to argue for ratification of the Constitution that emerged. His comments were particularly directed to New Yorkers.

[6] Prior to Rucho, there were opinions by individual Justices that expressed this view, but there had not been a majority of Justices willing to rule in this manner.

[7] They refer, for example, to the movement of some members from the House to the Senate, sizes of the states in which the Senators hail from and comparability problems regarding voting scores estimated from disjoint sets of votes and legislators (noting that using Common space NOMINATE scores and adjusted ADA scores contain assumptions that are not “testable”).

[8] Their method is not what is proposed in this paper. They used blocks within counties to run a computerized simulation. The suggestion here is to have two or more candidates to run county-wide in large counties.

[9] See the discussion below regarding the comment by Professor Engstrom, i.e., that it has been a longstanding “front burner question” as to whether gerrymandering has reduced the number of competitive districts.

[10] Per the House of Representatives website: https://www.house.gov/representatives

[11] Per the U.S. Census Bureau: https://www.census.gov/quickfacts/NY

[12] Per the U.S. Census Bureau: https://www.census.gov/quickfacts/newyorkcountynewyork?

[13] District 13: https://censusreporter.org/profiles/50000US3613-congressional-district-13-ny/. District 12: https://censusreporter.org/profiles/50000US3612-congressional-district-12-ny/