Robyn Renee Essex, plaintiff, v. Kris W. Kobach, Kansas Secretary of State, defendant : case no. 12-4046, in the United States District Court for the District of Kansas : south central Kansas intervenors' post trial brief.

"This Court's has a duty to draw a series of voter district maps because the Legislature abdicated theirs in the first instance. Because the Court is not a legislature, its universe of considerations is smaller and devoid of political machinations described by some trial witnesses. In discharging its constitutional responsibility, this Court is not casting the tie-breaking vote between competing factions. Instead, this Court's plan must attain de minimis deviations not available under Buffalo 30 Revised. In this Post-Trial Brief, Intervenors will address the constitutionality of Senate Districts in south-central Kansas. The law as applied to the evidence establishes that the Buffalo 30 plans are unconstitutional."