'Putting all federalist routes together, courts, voter initiatives, laws and elections reform is actually possible in the vast majority of states , even without the Supreme Court’s help. The elections clause of the Constitution gives states broad authority over redistricting as longas the actions do not run afoul of federal law. Justice Roberts conceded that states can act on their own by “actively addressing the issue through state constitutional amendments and legislation.” Since the GOP and their designates control the Supreme Court, the Senate and the presidency, reformers should embrace what the dean of Yale Law School, calls “progressive federalism.” We found27 instances in which a district map was overturned on the basis of state law, like in Pa. citing the state Constitution’s free and equal elections clause, a phrase that is also found in 27 other state Constitutions."