1. Bruce Cain, declare as follows: …

2. Based on my study of redistricting, I believe that the attempt to define unbiased and objective standards of political fairness is futile. The reasons for this are several. First, there are many possible standards of political fairness, and political scientists do not agree as to which is best, as is demonstrated by the contradictory arguments in the declarations of Professors Grofman and Baker. Professor Baker argues for a compactness criterion while Professor Grofman disparages the use of what he terms “formal criteria” such as the shape of district lines and proposes instead a seats-votes measure. Secondly, the two standards of political fairness proposed by Grofman and Baker will prove contradictory in many circumstances, and this will force the courts to choose between them. Thirdly, the proposed standards are inconsistent with other redistricting criteria—particularly, with the court's efforts in the last decade to protect racial and ethnic minority voting strength. Finally, attempts to use fairness formulae are fundamentally flawed and impractical: they underestimate the many complex factors that determine the outcome of an election and overestimate the capacity of social scientists to predict future electoral outcomes.