At least 25 other state constitutions require elections to be "free and equal" or "free and open," according to Bernard Grofman and Jonathan Cervas, political scientists at the University of California, Irvine. "So you're likely to see more litigation at the state level," Cervas said. "That had never been the route until Pennsylvania." One exception: Florida, where voters approved a constitutional amendment in 2010 explicitly banning partisan gerrymandering.


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