With the Supreme Court decision in Easley v. Cromartie, the 1990s round of redistricting litigation came to an end just in time for the new decade's round to commence. Looking back upon the Court decisions from the 1990s as well as the extensive scholarly commentary on them, anyone new to the field of voting rights in the United States might wonder how the Voting Rights Act, which was a straightforward attempt to remedy indisputably unjust political practices, could have given rise to the I-85 district in North Carolina.