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Three years after recognizing a new cause of action for racial redistricting in Shaw v. Reno,' the Supreme Court's voting rights jurisprudence still teeters on the brink of legal incoherence and political chaos. Concerned about the new extremes to which self-interested redistricting has been taken in the 1990s-particularly, but not exclusively, for racial purposes-the Court has been struggling to articulate legal principles that might fix acceptable boundaries on the power of politicians to define their constituencies.But last Term's unsurprising decisions striking down districts in North Carolina and Texas,3 like the previous Term's decision invalidating a Georgia congressional district,4 suggest that these principles remain disturbingly elusive. 5 To be sure, some speculations have been publicly confirmed, most notably that the fivemember majority crafting these new constitutional constraints is itself profoundly fragmented.' Yet the precise extent to which election districts can

Principled Limitations on Racial and Partisan Redistricting