voters which is too small. One extreme example is Waupun, Wisconsin, where two city council districts are made up of 61% and 76% incarcerated people, but as of 2019, neither elected representative has visited the local prisons. "Prison gerrymandering" has been criticized for distorting racial demographics and, as a result, political representation. A 2021 article in The New York Times argued that, as prisoners are disproportionately people of color from urban areas incarcerated in rural areas, "counting people where they’re imprisoned takes political power away from racial minorities in cities and transfers it to whites in rural areas." Reform efforts In 2018, the Census Bureau announced that it would retain the policy, asserting that the policy "is consistent with the concept of usual residence, as established by the Census Act of 1790," but also conceding assistance to states who wish to 'move' their prisoner population back to the prisoners' pre-incarceration addresses for redistricting and other purposes". A number of states have since ordered their state governments to recognize incarcerated persons as residents of their pre-incarceration homes for the sake of legislative and congressional redistricting at all levels. These include the states of Maryland and New York in time for the 2010 census. States that made similar orders in time for the 2020 census include California (2011), Delaware (2010), Nevada (2019), Washington (2019), New Jersey (2020), Colorado (2020), Virginia (2020) and Connecticut (2021) Additionally, Colorado (2002), Michigan (1966), Tennessee (2016) and Virginia (2013) have passed laws restricting counties and municipalities from (or allowing counties and municipalities to avoid) prison-based redistricting, and Massachusetts passed a 2014 resolution requesting the Census Bureau to end the practice of counting prisoners in their incarceration districts. Pennsylvania's legislative redistricting committee voted in 2021 to draw new legislative maps which avoid prison gerrymandering, as did Rhode Island's legislative redistricting committee in 2022 for legislative and congressional maps. Montana's committee also voted to avoid prison gerrymandering. Remedies Various political and legal remedies have been used or proposed to diminish or prevent gerrymandering in the country. Neutral redistricting criteria Various constitutional and statutory provisions may compel a court to strike down a gerrymandered redistricting plan. At the federal level, the Supreme Court has held that if a jurisdiction's redistricting plan violates the Equal Protection Clause or Voting Rights Act of 1965, a federal court must order the jurisdiction to propose a new redistricting plan that remedies the gerrymandering. (Under