Lamone v. Benisek were decided on June 27, 2019, which, in the 5–4 decision, determined that judging partisan gerrymandering cases is outside of the remit of the federal court system due to the political questions involved. The majority opinion stated that extreme partisan gerrymandering is still unconstitutional, but it is up to Congress and state legislative bodies to find ways to restrict that, such as through the use of independent redistricting commissions. State courts The Pennsylvania Supreme Court ruled in League of Women Voters of Pennsylvania v. Commonwealth of Pennsylvania that gerrymandering was unconstitutional, ruling that the districts drawn to favor Republicans violated "free and equal" Elections Clause of the Pennsylvanian constitution and redrew the districts after the state government failed to comply with the deadline in its order to redraw. The U.S. Supreme Court denied to hear the challenge and allowed the Pennsylvania Supreme Court's maps to remain in place. In October 2019, a three-judge panel in North Carolina threw out a gerrymandered electoral map, citing violation of the constitution to disadvantage the Democratic Party. Bipartisan gerrymandering Bipartisan gerrymandering, where redistricting favors the incumbents in both the Democratic and Republican parties, became especially relevant in the 2000 redistricting process, which created some of the most non-competitive redistricting plans in American history. The Supreme Court held in Gaffney v. Cummings (1973) that bipartisan gerrymanders are constitutionally permissible under the Equal Protection Clause. Racial gerrymandering Racial makeup can be used as a means to create gerrymanders. There is overlap between racial and partisan gerrymandering, as minorities tend to favor Democratic candidates; the North Carolina redistricting in Rucho v. Common Cause was such a case dealing with both partisan and racial gerrymanders. However, racial gerrymanders can also be created without considerations of party lines. Negative "Negative racial gerrymandering" refers to a process in which district lines are drawn to prevent racial minorities from electing their preferred candidates. Between the Reconstruction Era and mid-20th century, white Southern Democrats effectively controlled redistricting throughout the Southern United States. In areas where some African-American and other minorities succeeded in registering, some states created districts that were gerrymandered to reduce the voting impact of minorities. Minorities were effectively deprived of their franchise into the 1960s. With the passage of the Voting Rights Act of 1965 and its subsequent amendments, redistricting to carve maps to intentionally diminish the power of voters who were in a racial or linguistic