types of gerrymandering and the standards that should be used to determine which redistricting maps are unconstitutional. The United States Supreme Court has affirmed in Miller v. Johnson (1995) that racial gerrymandering is a violation of constitutional rights and upheld decisions against redistricting that is purposely devised based on race. However, the Supreme Court has struggled when partisan gerrymandering occurs (Vieth v. Jubelirer (2004) and Gill v. Whitford (2018)). A landmark decision, Rucho v. Common Cause (2019), ultimately decided that questions of partisan gerrymandering represent a nonjusticiable political question, which cannot be dealt with by the federal court system. That decision leaves it to states and to Congress to develop remedies to challenge and to prevent partisan gerrymandering. Some states have created independent redistricting commissions to reduce political drivers for redistricting. The research department of the nonpartisan nonprofit anti-corruption organization RepresentUs issues a Redistricting Report Card which rates the level of gerrymandered distortion of congressional district maps within each state, and its research suggests that wide swaths of the public "across partisan lines" are dissatisfied with gerrymandering and are ready for substantive reforms. Partisan gerrymandering Origins (1789–2000) Partisan gerrymandering, which refers to redistricting that favors one political party, has a long tradition in the United States. Starting from the William Cabell Rives in mid-19th century it is often stated that it precedes the 1789 election of the First U.S. Congress: namely, that while Patrick Henry and his Anti-Federalist allies were in control of the Virginia House of Delegates in 1788, they drew the boundaries of Virginia's 5th congressional district in an unsuccessful attempt to keep James Madison out of the U.S. House of Representatives. However, in early 20th century it was revealed that this theory was based on incorrect claims by Madison and his allies, and recent historical research disproved it altogether. The word gerrymander (originally written "Gerry-mander") was used for the first time in the Boston-Gazette (not to be confused with the Boston Gazette) on March 26, 1812, in reaction to a redrawing of Massachusetts state senate election districts under the then-governor Elbridge Gerry (1744–1814), who signed a bill that redistricted Massachusetts to benefit his Democratic-Republican Party. When mapped, one of the contorted districts to the north of Boston was said to resemble the shape of a salamander. The coiner of the term "gerrymander" may never be firmly established. Historians widely believe that the Federalist newspaper editors Nathan Hale,