to develop such a method to determine if a district map was a justiciable partisan gerrymandering, as to prepare for the 2020 elections. Many early attempts failed to gain traction the court system, focusing more on trying to show how restricting maps were intended to favor one party or disfavor the other, or that the redistricting eschewed traditional redistricting approaches. Around 2014, Nicholas Stephanopoulos and Eric McGhee developed the "efficiency gap", a means to measure the number of wasted votes (votes either far in excess of what we necessary to secure a win for a party, or votes for a party that had little chase to win) within each district. The larger the gap of wasted votes between the two parties implied the more likely that the district maps supported a partisan gerrymandering, and with a sufficiently large gap it would be possible to sustain that gap indefinitely. While not perfect, having several potential flaws when geography of urban centers were considered, the efficiency gap was considered to be the first tool that met both Kennedy's and Stevens' suggestions. The first major legal test of the efficiency gap came into play for Gill v. Whitford (2016). The District Court in the case used the efficiency gap statistic to evaluate the claim of partisan gerrymander in Wisconsin's legislative districts. In the 2012 election for the state legislature, the efficiency gap was 11.69% to 13% in favor of the Republicans. "Republicans in Wisconsin won 60 of the 99 Assembly seats, despite Democrats having a majority of the statewide vote." The disparity led to the federal lawsuit Gill v. Whitford, in which plaintiffs alleged that voting districts were gerrymandered unconstitutionally. The court found that the disparate treatment of Democratic and Republican voters violated the 1st and 14th amendments to the U.S. Constitution. The District Court's ruling was challenged and appealed to the Supreme Court of the United States, which in June 2017 agreed to hear oral arguments in the case in the 2017–2018 term of court.The case was then dismissed due to lack of standing for the plaintiffs with no decision on the merits being made. The case was then remanded for further proceedings to demonstrate standing. While previous redistricting cases before the Supreme Court have involved the Equal Protection test, this case also centers on the applicability of the First Amendment freedom of association clause. Benisek v. Lamone was a separate partisan