sex, race, or occupation than in terms of where they live per se. However, single-member, simple plurality systems still have certain undeniable advantages over PR systems (e.g., the exaggerated majority effect tends to make governance easier), and the Madisonian fear of excessive group factionalism that is pervasive, if not always explicitly acknowledged in the American middle class, will probably prevent any wholesale transition to proportional representation in any case. Also, as we have seen from the futile attempts of the Liberal-SDP alliance to alter the electoral rules of the British system, single-member systems have a strong inertial force centered on a most powerful human motive--that is, the desire of incumbent politicians to stay in office. Incumbents are unlikely to give up the system that elected them for the uncertainty of a more proportional world. Resistance to abandoning SMSP is also likely to come from regional and local interests, which tend to flourish under single-member simple-plurality rules. Thus, given these forces, institutional shifts toward proportional rules are likely to happen very slowly, if at all.
In the meanwhile, the Court has indicated by its decisions in Davis v. Bandemer and Thornburg v. Gingles that it will maintain a high threshold of intervention, giving the political system much leeway to deal with the demands of various groups for fair representation. Formally constitutionalizing group claims to proportional representation may be bad law, but informally accommodating various groups may be good politics. In any case, it seems that the recent redistricting decisions have given political entities enough leeway to find out for themselves.