the courts have generally avoided a strong ruling for fear of showing political bias towards either of the major parties. The Supreme Court had ruled in Davis v. Bandemer (1986) that partisan gerrymandering violates the Equal Protection Clause and is a justiciable matter. However, in its decision, the Court could not agree on the appropriate constitutional standard against which legal claims of partisan gerrymandering should be evaluated. Writing for a plurality of the Court, Justice White said that partisan gerrymandering occurred when a redistricting plan was enacted with both the intent and the effect of discriminating against an identifiable political group. Justices Powell and Stevens said that partisan gerrymandering should be identified based on multiple factors, such as electoral district shape and adherence to local government boundaries. Justices O'Connor, Burger, and Rehnquist disagreed with the view that partisan gerrymandering claims were justiciable and would have held that such claims should not be recognized by courts. Lower courts found it difficult to apply Bandemer, and only in one subsequent case, Party of North Carolina v. Martin (1992), did a lower court strike down a redistricting plan on partisan gerrymandering grounds. The Supreme Court revisited the concept of partisan gerrymandering claims in Vieth v. Jubelirer (2004). While the Court upheld that partisan gerrymandering could be justiciable, the justices were divided in this specific case as no clear standard against which to evaluate partisan gerrymandering claims emerged. Writing for a plurality, Justice Scalia said that partisan gerrymandering claims were nonjusticiable. A majority of the court would continue to allow partisan gerrymandering claims to be considered justiciable, but those justices had divergent views on how such claims should be evaluated. Justice Anthony Kennedy, in a concurrence with the plurality, offered that a manageable means to determine when partisan gerrymandering occurred could be developed, and challenged lower courts to find such means. The Court again upheld that partisan gerrymandering could be justiciable in League of United Latin American Citizens v. Perry (2006). While the specific case reached no conclusion of whether there was partisan gerrymandering, Justice John Paul Stevens's concurrence with the plurality added the notion of partisan symmetry, in that the electoral system should translate votes to representative seats with the same efficiency regardless of party. Opinions from Vieth and League, as well as the strong Republican advantage created by its REDMAP program, had led to a number of political scholars working alongside courts