Rucho v. Common Cause, this does not include purely partisan gerrymandering, but can include maps drawn to promote white supremacy, for example.) If the jurisdiction fails to propose a new redistricting plan, or its proposed redistricting plan continues to violate the law, then the court itself must draw a redistricting plan that cures the violation and use its equitable powers to impose the plan on the jurisdiction. In the Supreme Court case of Karcher v. Daggett (1983), a New Jersey redistricting plan was overturned when it was found to be unconstitutional by violating the constitutional principle of one person, one vote. Despite the state claiming its unequal redistricting was done to preserve minority voting power, the court found no evidence to support this and deemed the redistricting unconstitutional. At the state level, state courts may order or impose redistricting plans on jurisdictions where redistricting legislation prohibits gerrymandering. For example, in 2010 Florida adopted two state constitutional amendments that prohibit the Florida Legislature from drawing redistricting plans that favor or disfavor any political party or incumbent. Ohio residents passed an initiative in 2018 that requires the redistricting maps to have at least 50% approval by the minority party in the legislature. Moon Duchin, a Tufts University professor, has proposed the use of metric geometry to measure gerrymandering for forensic purposes. Redistricting commissions Some states have established non-partisan redistricting commissions with redistricting authority. Washington, Arizona, and California have created standing committees for redistricting following the 2010 census. However, it has been argued that the Californian standing committee has failed to end gerrymandering. Rhode Island and the New Jersey Redistricting Commission have developed ad hoc committees, but developed the past two decennial reapportionments tied to new census data. The Arizona State Legislature challenged the constitutionality of a non-partisan commission, rather than the legislature, for redistricting. In Arizona State Legislature v. Arizona Independent Redistricting Commission (2015), the United States Supreme Court upheld the constitutionality of non-partisan commissions. Redistricting algorithms Some have proposed using a computer program to draw districts. Under this approach, mapmakers would select a redistricting algorithm to draw districts based on a predetermined set of instructions. A computer-based approach offers the potential to prevent gerrymandering by removing human mapmakers from the process. The challenge is agreeing on a redistricting algorithm. Many of the choices that go into the design of a redistricting algorithm have predictable political outcomes, so political bias can still