Defendants attempt to use this direct appeal to make it more difficult to prove racial gerrymandering claims whenever legislators invoke “partisanship” as a basis for the gerrymander. But this Court has long made clear that partisan ends cannot be achieved via predominantly race-based means. It should reject Defendants’ invitation to rewrite that precedent and to erect an even higher bar for plaintiffs seeking to prove racial gerrymandering claims where partisan goals were involved. This Court should affirm the District Court’s conclusion that Congressional District 1 (“CD1”) was an impermissible racial gerrymander.