Robyn Renee Essex, plaintiff, v. Kris W. Kobach, Kansas Secretary of State, defendants : Civil action case no. 12-CV-04046-KHV-DJW, in the United States District Court for the District of Kansas : plaintiff intervenor John W. Bradford's memorandum about the application of constitutional principles to the Court's consideration of redistricting plans for the Kansas Senate.

"To be clear, even though the United States Supreme Court has said that in drawing lines for a legislative districting plan the integrity of political subdivisions is a permissible prudential consideration justifying departures from strict population equality, White v. Weiser, 412 U.S. 783, 795-97, 37 L. Ed. 2d 335, 93 S. Ct. 2348 (1973); Mahan v. Howell, 410 U.S. 315, 321-26, 35 L. Ed. 2d 320, 93 S. Ct. 979 (1973); Reynolds v. Sims, 377 U.S. 533, 578-81 (1964), Intervenor John Bradford has found no case, and, therefore, does not argue, that the observance of county lines is a mandatory consideration under the Constitution. See Favors v. Cuomo, 2012 U.S. Dist. LEXIS 68634, ** 25-27 (E.D.N.Y. May 16, 2012) (rejecting intervenor's argument that a plan which divided intervenor's hometown into three districts diminished intervenor's voting power without due process of law or violated the one person, one vote requirement of the Equal Protection Clause and citing cases)."