With this filing Roland appears as the only litigant who does not represent a special interest group using the case in a struggle for power. Rather than argue the merits of particular maps, he argues for a totally new process in which humans are taken out of the map-drawing process and the job is left to a computer set to draw maps at random.
Please spread this message widely.
The core of the proposal follows:
Intervenor moves the Court adopt the following solution:
(1) Constraints on the maps. The smallest unit of area shall be the voting precinct, as presently established by law, which shall be of equal population within a county and not differ in population from county to county by more than necessary to accommodate counties of low population.
(a) Equipopulous. The population of each district shall not differ from that of any of the other districts by more than a factor of 0.0001 or the margin of error of the census count, whichever is less.
(b) Aligned. Only counties with a population of more than a factor of between 0.1 and 1/3, initially 1/3 unless or until amended by the State Legislature, of the average population of a congressional district, may be split between districts, unless a larger number of counties must be split to meet the specification (a) above, and a smaller number of counties shall be split if specification (a) can be met.
(c) Contiguous. Districts must be contiguous, so that there is always at least one continuous line of points connecting any two points within the district, and no connection between parts consists only of a line or point.
(d) Simply connected. Districts must be simply connected, so that any continuous loop of points within the district may be shrunk to a point within the district without crossing boundary lines. This means no holes in districts, and no surrounding of one district by another.
(e) Compact. Districts shall be maximally compact, resulting from a running time of at least 6 and not to exceed 24 hours, adjusted for improvements in processor speed, with compactness defined by minimizing the value of p²/4πA, where p = perimeter and A = area of the district, with all other values remaining constant or improving. For an area bounded by a circle the value of this expression is 1.
(2) Procedures. District maps shall be generated and finally adopted mechanically with minimal human intervention using a computer program.
(a) The software to be used initially shall be the TARGET software already developed, but may be modified or replaced at the discretion of the State Legislature thereafter. But source code for the production version of any computer redistricting software and the database shall be made accessible for downloading from the web site of the State for public examination and comment, and to be shared with other states and communities, at no cost other than storage media.
(b) The State shall establish and maintain adequate safeguards to insure that no unauthorized alterations are made in the software or interventions made in the running of it that might bias the output. As soon as feasible, a version of the present database containing only information needed to satisfy the public constraints established herein or by act of the State Legislature shall be prepared, and made the only database accessible to the redistricting program during the generation of maps for official selection.
(c) A commission or grand jury, hereinafter called the “Redistricting Commission”, consisting of 23 individuals, either drawn at random from all qualified voters in the State, or from members of the Texas House of Representatives, at the discretion of the Texas Secretary of State, unless or until the State Legislature shall provide otherwise, shall supervise the redistricting process.
(d) Initially, and thereafter after the most recent decennial census results are available, and prior to filing deadlines, the Redistricting Commission shall cause to be randomly generated at least three times as many maps as there are members of the Redistricting Commission.
(e) Each Commission member shall have the right to reject or strike one map from among the maps randomly generated during the current redistricting session.
(f) One map shall be selected at random from among the randomly generated maps that remain after strikes, and that map shall become the district map for the next election without amendment or debate.