Bandemer, Shaw, and Miller reflect the absence of a theoretical framework for implementing group considerations. Sensing the need to supplement individual voting rights with an attunement to group voices, the Court is rightly apprehensive over the polarizing potential inherent in formally recognizing those collective interests. The group right to representation remains undetermined, as the Court struggles for a theory by which it can position groups within the complex system of representation.
The challenge is to broaden and inform the Court's narrow conceptualization of representation. This requires a thorough understanding of the group theory of political activity and the pluralist definition of democracy that it has propagated. The solution to the perplexing problems of group representation lies in the pluralist account of government and the weaknesses in the theory and practice of pluralism. Before the Court can constitutionally situate politically active groups and parties in the labyrinth of representation, it must have the requisite understanding of group theory and pluralism, and the dilemmas they raise. It is that task to which we now turn.