DEMOGRAPHIC PARADOXES IN THE LOS-ANGELES VOTING-RIGHTS CASE

As local jurisdictions redistrict in the 1990s, those with a complex demographic mosaic like Los Angeles County's must exercise particular care in fulfilling three legal obligations: first, to protect the voting power of citizens; second, to ensure equal representation for equal numbers of persons; and third, to avoid diluting the voting strength of a protected group. Courts draw on demographic analysis to quantify these legal standards. This article illustrates how such analysis can inform-and potentially confuse-judicial review in Section 2 voting rights claims. In Los Angeles County, efforts to enhance the voting strength of Hispanics risk an equal protection challenge by minority and nonminority citizens in the remaining districts, whose votes get devalued. Demographic analysis exposes potential limitations in using "total population" as the apportionment base and is essential in gauging the actual compactness of a jurisdiction's minority voters.