A multimember district (MMD) is a political district with more than one representative. European countries with proportional representation divide multiple representatives proportionally by party vote, normally producing many small, doctrinaire parties and volatile, schismatic governments. In United States MMDs, at-large, winner-take-all elections have been the rule, notably with electoral college delegations. Winner-take-all puts more than proportional value on shiftable votes. Scholars believe that it has helped produce the American pattern of stable, center-seeking, two-party coalitions attentive to minorities who can form part of a winning coalition.
A ten-member, winner-take-all MMD offers less demographic variety—and less direct claim on any particular representative—than ten single-member districts; so MMDs have often been attacked for depersonalizing representation and submerging minorities. On the other hand, voters in MMDs have a mathematical advantage over voters in single-member districts (SMDs) because a 110 vote for ten representatives has more chance of affecting the overall election outcome than a full vote for one representative. Moreover, MMD representatives, who answer to one large constituency rather than to ten small ones, are thought more likely to vote as a bloc than SMD representatives. Hence, an MMD voter may have less access to his representative than does an SMD voter, but he also may have more power over electoral and legislative outcomes.
MMDs share with gerrymanders the "standards problem": the incommensurability of the various ways in which dilution or concentration of a group can enhance or diminish the group's power for different purposes. Short of ordering proportional representation, there is no way to equalize a group's (or a group member's) effective power. Accordingly, the Supreme Court has been cautious in intervening against MMDs, as it has against gerrymanders. In Delaware v. New York (1966) it was unmoved by Delaware's argument that New York voters, with sixty-four delegates to the Electoral College, has 2.3 times as much chance to affect the election outcome as Delaware voters, with only three delegates.
Likewise, with the exceptions of judicially created MMDs and legislatively created ones drawn with the proven intent of submerging minorities, the Court has been tolerant of MMDs, even where their effect has been to submerge minorities. In Whitcomb v. Chavis (1971) and mobile v. bolden (1980) the Court held that submerging a minority is not per se a violation of the fourteenth or fifteenth amendment. Purposeful discrimination must also be shown, as in White v. Regester (1973) and rogers v. lodge (1982), where the plaintiffs demonstrated intentional discrimination against minority groups. Congressional critics (of the Mobile case) in 1982 succeeded in amending the voting rights act of 1965 to make racially disproportionate election results one "circumstance" relevant to the determination of a violation of the act. The amendment added a proviso that racially proportional representation is not required, but it left to the courts the task of giving meaning to its calculatedly uncertain operative language.
Ward E. Y. Elliot
Banzhaf, John E. 1966 Multi-Member Electoral Districts—Do They Violate the "One Man, One Vote" Principle? Yale Law Journal 75:1309–1338.
Elliot, Ward E. Y. 1975 The Rise of Guardian Democracy: The Supreme Court's Role in Voting Rights Disputes, 1845–1969. Cambridge, Mass.: Harvard University Press.