The Wisconsin redistricting plan in Whitford resulted in disproportionate representation of Republicans in the State legislature. In 2012, Democrats won a majority of the popular vote (51.4%) but received only 39 seats in the state’s 99-member legislature. In the same election, Republicans won only 48.6% of the statewide vote, but gained 60 seats in the legislature. In 2014, Democrats won approximately 48% of the vote, and received only 36 seats, while Republicans received 52% of the vote, but gained 63 seats. Determining what criteria should be used in evaluating a discriminatory effect on voter representation that should be considered unconstitutional is very difficult, because no plans that divide voters into districts will ever produce perfectly proportional representation of voters from different parties in the legislature, and considerations such as geographic concentration of voters in cities may further distort voter representation.