20
ALLEN v. MILLIGAN
Opinion of the Court
was 27%, but there was only one majority-minority district.
Id., at 906. To comply with the VRA, Georgia thought it
necessary to create two more majority-minority districts—
achieving proportionality. Id., at 920–921. But like North
Carolina in Shaw, Georgia could not create the districts
without flouting traditional criteria. One district “centered
around four discrete, widely spaced urban centers that
ha[d] absolutely nothing to do with each other, and
stretch[ed] the district hundreds of miles across rural counties and narrow swamp corridors.” 515 U. S., at 908. “Geographically,” we said of the map, “it is a monstrosity.” Id.,
at 909.
In Bush v. Vera, a plurality of the Court again explained
how traditional districting criteria limited any tendency of
the VRA to compel proportionality. The case concerned
Texas’s creation of three additional majority-minority districts. 517 U. S., at 957. Though the districts brought the
State closer to proportional representation, we nevertheless
held that they constituted racial gerrymanders in violation
of the Fourteenth Amendment. That was because the districts had “no integrity in terms of traditional, neutral redistricting criteria.” Id., at 960. One of the majority-black
districts consisted “of narrow and bizarrely shaped tentacles.” Id., at 965. The proposed majority-Hispanic district
resembled “a sacred Mayan bird” with “[s]pindly legs
reach[ing] south” and a “plumed head ris[ing] northward.”
Id., at 974.
The point of all this is a simple one. Forcing proportional
representation is unlawful and inconsistent with this
Court’s approach to implementing §2. The numbers bear
the point out well. At the congressional level, the fraction
of districts in which black-preferred candidates are likely to
win “is currently below the Black share of the eligible voter
population in every state but three.” Brief for Professors
Jowei Chen et al. as Amici Curiae 3 (Chen Brief ). Only one