“…As we have seen, proportional representation is not the aim of any modern measure of electoral fairness, or any claim brought before the court in the 2019 districting cases (It may indeed have been an issue 33 years ago, when Justice O'Connor wrote the words Roberts quotes in her concurrence in Davis v. Bandemer) Indeed, one measure arising in contemporary cases, the efficency gap, is incompatible with proportional representation, while the ensemble sampling methods (correctly, in my view) are orthogonal to proportional representation. In some case a map that yields proportional-representation outcomes would be licensed by those methods; in other cases, like U.S. congressional districts in Massachusetts, a map yielding proportional representation would be flagged as an extreme outlier [11].…”