The 1980s California congressional plans are not shown to be gerrymanders by the fact that the 1982 results were grossly disproportional to the votes of the electorate, nor by the fact that these plans each have only a very small number of seats where both parties have reasonable chances for the victory, nor by the fact that each plan is characterized by tortuously shaped districts, e.g., in San Diego and Northern California, which have no justification in terms of minority protection or in preserving city boundaries intact, although all three of these statements are true. It is well recognized that single member districts cannot be expected to yield proportionality between a party's vote percentage and the percentage of seats it wins (indeed, defense experts cite my own work on just this point); and it is also recognized that neither the absence of competition, nor the existence of ill-compact districts, make a gerrymander in and of themselves. Each of these factors, rather, is an indicator of possible gerrymandering efforts. When all three of these factors are found together with others (e.g., a plan passed in frantic haste by a partisan majority with no input from the minority party, a plan with clear discriminatory impact on the incumbents of the minority party) we have evidence for the conclusion that a plan that looks like a gerrymander, was intended to be a gerrymander, and has the effects of a gerrymander, is a gerrymander.