Consideration may be given to the preservation of incumbent-constituency relations by recognition of the residence of incumbents and their history in representing certain areas. The court will review all plans in light of these criteria and will evaluate how well each plan conforms to the criteria. Any plan submitted to the court by a citizen for its consideration should be a complete plan-i.e., it should show the full number of districts and should redistrict the entire county. The court may decline to consider any plan that is not a complete plan. All plans submitted by citizens, as well as plans submitted by staff, consultants, and members of the court should conform to these criteria.
Functional compactness is a sometimes controversial notion that has appeared in some cases.
We do not anticipate that we will rely heavily on functional compactness, but there may be instances in which it comes into play. For example, we might be able to draw a very geographically compact district by including land on both sides of a river. If, however, the nearest bridge is several miles away, our geographically compact district may not be functionally compact. Saying that compactness has a functional dimension gives us flexibility to address this type of situation. Retrogression is the standard used by the Department of Justice and the courts to determine if a plan can be precleared under section 5 of the Voting Rights Act.