In a series of lawsuits during the 1990s, federal courts in the United Stat
es rejected congressional election districts that had both extremely irregu
lar boundaries and nonwhite: majorities. In particular, courts ruled that t
he shape oi these districts - which they characterized as "bizarre" and non
compact - demonstrated that states had unconstitutionally classified voters
by race. These legal cases reflect a fundamental tension in American polit
ical culture between universalistic citizenship and particularistic racial
identity. Universalistic concepts that embrace numeric political representa
tion, geometric standards of shape, and the "liberal self" share an underst
anding of the individual as the basic unit of political representation and
define this individual by the ability to make rational choices. In contrast
, concepts of particularistic identity that emphasize the importance of "re
gional community representation," informal visual standards of shape, and p
lace-based or regional attachments view communities as tile basic unit of p
olitical representation, and believe that individual identity is primarily
constituted by membership in communities. Although some participants in the
redistricting litigation have advocated notions of community based on raci
al solidarity, federal courts have only recognized such claims to the exten
t chat these communities are defined by regional attachments. This suggests
that tile importance of regional attachments remains firmly entrenched in
the American political system, despite tile ascendance of "placeless" numer
ic representation. Notwithstanding the impassioned rhetoric on both sides,
the effect of these cases is ambiguous for two reasons. First, the creation
of nonwhite majority districts is a problematic strategy of political empo
werment; second, the decisions do not directly address the underlying issue
s of segregation and racial inequality.