26 RUCHO v. COMMON CAUSE Opinion of the Court est in voting.” 348 F. Supp. 3d, at 523–524. To begin, there are no restrictions on speech, association, or any other First Amendment activities in the districting plans at issue. The plaintiffs are free to engage in those activities no matter what the effect of a plan may be on their district. The plaintiffs’ argument is that partisanship in districting should be regarded as simple discrimination against supporters of the opposing party on the basis of political viewpoint. Under that theory, any level of partisanship in districting would constitute an infringement of their First Amendment rights. But as the Court has explained, “[i]t would be idle . . . to contend that any political consideration taken into account in fashioning a reapportionment plan is sufficient to invalidate it.” Gaffney, 412 U. S., at 752. The First Amendment test simply describes the act of districting for partisan advantage. It provides no standard for determining when partisan activity goes too far. As for actual burden, the slight anecdotal evidence found sufficient by the District Courts in these cases shows that this too is not a serious standard for separating constitutional from unconstitutional partisan gerrymandering. The District Courts relied on testimony about difficulty drumming up volunteers and enthusiasm. How much of a decline in voter engagement is enough to constitute a First Amendment burden? How many door knocks must go unanswered? How many petitions unsigned? How many calls for volunteers unheeded? The Common Cause District Court held that a partisan gerrymander places an unconstitutional burden on speech if it has more than a “de minimis” “chilling effect or adverse impact” on any First Amendment activity. 318 F. Supp. 3d, at 930. The court went on to rule that there would be an adverse effect “even if the speech of [the plaintiffs] was not in fact chilled”; it was enough that the districting plan “makes it