EG's State Senate Thread

[ElectionsGuy]

Texas:



1: 66.1% Obama, 33.9% McCain = Safe D
2: 74.9% McCain, 25.1% Obama = Safe R
4: 69.4% Obama, 30.6% McCain = Safe D
9: 54.6% McCain, 45.4% Obama = Likely R
10: 66.2% McCain, 33.8% Obama = Safe R
18: 59.9% McCain, 40.1% Obama = Safe R
19: 64.9% McCain, 35.1% Obama = Safe R
28: 70.8% McCain, 29.2% Obama = Safe R
29: 69.9% McCain, 30.1% Obama = Safe R
30: 74.8% McCain, 25.2% Obama = Safe R
31: 72.8% McCain, 37.2% Obama = Safe R

Rio Grande Valley Close-Up:



3: 70.2% Obama, 29.8% McCain = Safe D

San Antonio/Austin Close-Up:



5: 71.4% Obama, 28.6% McCain = Safe D
6: 54.8% McCain, 45.2% Obama = Likely R
7: 68.6% Obama, 31.4% McCain = Safe D
8: 56.4% McCain, 43.6% Obama = Safe R

Houston Close-Up:



11: 74.4% Obama, 25.6% McCain = Safe D
12: 76.9% Obama, 23.1% McCain = Safe D
13: 59.8% Obama, 40.2% McCain = Likely D
14: 61.6% McCain, 38.4% Obama = Safe R
15: 72.5% McCain, 27.5% Obama = Safe R
16: 65.3% McCain, 34.7% Obama = Safe R
17: 65.6% McCain, 34.4% Obama = Safe R

Dallas/Fort Worth Close-Up:



20: 80.7% Obama, 19.3% McCain = Safe D
21: 62.0% Obama, 38.0% McCain = Safe D
22: 51.1% McCain, 48.9% Obama = Lean R
23: 56.3% McCain, 43.7% Obama = Safe R
24: 65.8% McCain, 34.2% Obama = Safe R
25: 63.0% McCain, 37.0% Obama = Safe R
26: 67.9% McCain, 32.1% Obama = Safe R
27: 69.3% McCain, 30.7% Obama = Safe R

21/31 = 67.7% R. The current state senate is 20-11 R. Removed from page two and re-posted here for order.

[Sol]

How many black majority districts are in that Florida map?

I'm also a little concerned that you don't have enough majority latino districts in south florida--it is a similar issue with regards to the south side in that respect.

[muon2]

In response to your codicil, is there anything in the amended statute suggesting that one can find discriminatory effect if neutral line drawing principles are followed? Has that ever been litigated? I keep asking that question. My point of view, my instinct, is that absent something more on point, with facts more on point (what really matters to lawyers is rulings versus fact patterns, not sweeping statements of a general rule, that can be interpreted a host of ways, and was written not really thinking about other fact patterns), if there are multiple maps choices following neutral principles, than one needs to go with the version that maxes minority districts ( at least until the spoils get proportional to population percentages, however that is defined). But that is the extent of it. I would love to argue this before SCOTUS as the rule they should adopt, to get rid of all of this confusion and gaming. It's just awful. It's time to end it.

I think my logic (and those I have listened to) derives from Mobile v Bolden and its aftermath. At that time Mobile elected its city commission at-large. Blacks sued under the VRA at that time saying that they could not elect a candidate of choice. SCOTUS found that blacks could now register and vote without hindrance and the at-large system was racially neutral. They held that the lack of a discriminatory purpose meant that the statute was not a violation of section 2. In response to the decision Congress amended the VRA to make discriminatory effect the standard. The amendment was written to bar facially neutral laws that had a demonstrable impact on a protected minority. Subsequently Mobile changed to single member districts, as did many other jurisdictions where there were significant minority populations.

Your hypothetical is whether this would apply to a system of neutral redistricting rules like the muon2 rules. My sense is that if the plaintiff's can show a disparate effect, such as having significantly fewer opportunities than the minority share of the CVAP population overall, then the ball goes to the state to defend against strict scrutiny. The fact that the rules are neutral isn't a shield under the 1982 VRA.

In some sense this played out in the IL congressional challenge in 2011. The Pubs asserted that there was no opportunity for Latinos to win more than IL-4 despite their growth to be the largest minority in the state. The Court (panel of the 7th circuit) found that there was an effect, but Dems claimed that a plan with 2 CDs at 59% HVAP wasn't feasible. The Pubs didn't submit a map to show that one was possible (they submitted one with just under 50% HVAP) and lost on their claim of a section 2 violation.

[Torie]

An at large voting system is not analogous in my view to neutral line drawing. Neutral line drawing allows for a variety of maps. Pick the one that helps the minorities the most. What you are essentially asserting is that if minority locations mean that reasonable line drawing must be thrown in the trash, I doubt SCOTUS will go there, particularly in this day and age. In reality, neutral line drawing will typically not have much of an adverse effect on minorities, since they tend to be concentrated in inner cities. The toughest case is where, which will be atypical, a minority is on both sides of a line, and to create a minority district, one must do an extra chop. The case is clearest for the first district. We may  have to wait a long time for a case however, generated by the Pubs doing what they tried to do in Illinois. Would a court have demanded another Hispanic CD that was able to elect an Hispanic, but was hideously erose, chopped all over the place, and involved non contiguous Hispanic nodes? That would be the question before the court.

In the case the Pubs lost in Illinois, did the court just focus on 50% HVAP not being sufficient - rather one needed 50% HCVAP, or even a figure higher than 50% HCVAP (if 59% HVAP was higher than 50% HCVAP), or did it also mention the chops and erosity? I do think within a jurisdiction, with respect to a contiguous minority population, one probably does need to go erose to create more minority districts, unless really grotesque perhaps.  That is because, at least in part, as we well know, measuring erosity is subject to a variety of interpretations and ways to measure.

We may have to wait a long time for a case, alas, because in many places, the Dems not maxing minority seats has no partisan impact, or political realities force them to max such seats within the parameters we are arguing about. An example of the former is Maryland, where the Steny Hoyer seat should be black under your standard, but isn't (except maybe not, since 2 black seats is probably proportional to the black population in Maryland), and an example of the latter is New York. However, in most places, with respect to blacks, they tend to be within the big city. It will also be rare, because since one has some choice as to where to chop, typically with neutral criteria, it will be possible to select the chop locations that max the number of minority seats.

I really cannot think of an instance when it comes to CD's anywhere, where there is likely to be a partisan battle over this issue at the moment, other than your example in Illinois, where it appears that the trigger was not in play, because the Hispanic population of the second CD was too low. But for legislative seats, the ground for this type of litigation might be more fertile.

[muon2]

An at large voting system is not analogous in my view to neutral line drawing. Neutral line drawing allows for a variety of maps. Pick the one that helps the minorities the most. What you are essentially asserting is that if minority locations mean that reasonable line drawing must be thrown in the trash, I doubt SCOTUS will go there, particularly in this day and age. In reality, neutral line drawing will typically not have much of an adverse effect on minorities, since they tend to be concentrated in inner cities. The toughest case is where, which will be atypical, a minority is on both sides of a line, and to create a minority district, one must do an extra chop. The case is clearest for the first district. We may  have to wait a long time for a case however, generated by the Pubs doing what they tried to do in Illinois. Would a court have demanded another Hispanic CD that was able to elect an Hispanic, but was hideously erose, chopped all over the place, and involved non contiguous Hispanic nodes? That would be the question before the court.

In the case the Pubs lost in Illinois, did the court just focus on 50% HVAP not being sufficient - rather one needed 50% HCVAP, or even a figure higher than 50% HCVAP (if 59% HVAP was higher than 50% HCVAP), or did it also mention the chops and erosity? I do think within a jurisdiction, with respect to a contiguous minority population, one probably does need to go erose to create more minority districts, unless really grotesque perhaps.  That is because, at least in part, as we well know, measuring erosity is subject to a variety of interpretations and ways to measure.

We may have to wait a long time for a case, alas, because in many places, the Dems not maxing minority seats has no partisan impact, or political realities force them to max such seats within the parameters we are arguing about. An example of the former is Maryland, where the Steny Hoyer seat should be black under your standard, but isn't (except maybe not, since 2 black seats is probably proportional to the black population in Maryland), and an example of the latter is New York. However, in most places, with respect to blacks, they tend to be within the big city. It will also be rare, because since one has some choice as to where to chop, typically with neutral criteria, it will be possible to select the chop locations that max the number of minority seats.

I really cannot think of an instance when it comes to CD's anywhere, where there is likely to be a partisan battle over this issue at the moment, other than your example in Illinois, where it appears that the trigger was not in play, because the Hispanic population of the second CD was too low. But for legislative seats, the ground for this type of litigation might be more fertile.

The magic number in IL federal suits is 59.2% HVAP. The court notes that was the value in the 1990 map and Gutierrez won and continues to win in that seat. The Dem plan had one CD at 65.9% HVAP and the Pub plan offered CDs of 59.4% and 46.5% HVAP. Even the Pub expert admitted that the 46.5% HVAP was not going to reach the 59% level by the next Census. A Pub map with an erose second Latino CD at 60% HVAP was available, but the Pubs did not use it in part because it didn't help their claim of political gerrymandering, which also lost.

I agree that it will be hard to find the test case you seek. All I would add is that SCOTUS viewed at-large districts as a neutral districting mechanism, which is how I think they would classify the muon2 rules. I read that as they saw no lines as a subset of lines in general.

[Torie]

At large voting is very different, because with polarized voting, it is a recipe for shutting out the minority entirely. And there is no good policy reason for it. There is a good policy reason for neutral line drawing, and the cases where it screws the minority will be rare, and even then, only at the margins when it comes to proportionality.

[muon2]

At large voting is very different, because with polarized voting, it is a recipe for shutting out the minority entirely. And there is no good policy reason for it. There is a good policy reason for neutral line drawing, and the cases where it screws the minority will be rare, and even then, only at the margins when it comes to proportionality.

True, but that wasn't relevant to the SCOTUS decision. To SCOTUS it was just a neutral districting principle, and at that time they found that it was not a violation of section 2. Because of the policy implications you mention Congress acted to change the VRA, but they didn't identify whether a neutral districting principle was good policy. Congress amended the VRA to say that any policy, good or not, that had a discriminatory effect was a violation. That effect includes anything that diminishes the minority's fair participation in the political process.

[Torie]

At large voting is very different, because with polarized voting, it is a recipe for shutting out the minority entirely. And there is no good policy reason for it. There is a good policy reason for neutral line drawing, and the cases where it screws the minority will be rare, and even then, only at the margins when it comes to proportionality.

True, but that wasn't relevant to the SCOTUS decision. To SCOTUS it was just a neutral districting principle, and at that time they found that it was not a violation of section 2. Because of the policy implications you mention Congress acted to change the VRA, but they didn't identify whether a neutral districting principle was good policy. Congress amended the VRA to say that any policy, good or not, that had a discriminatory effect was a violation. That effect includes anything that diminishes the minority's fair participation in the political process.

Than any lines, no matter how gross, under that interpretation, that do not max minority seats, would be deemed to have a discriminatory effect. I doubt SCOTUS would interpret the statute as amended as abandoning any semblance of a balancing test. Nor do I think any court has demanded gross lines. Rather, I think the courts would find any approach that is grounded on good public policy, even if it does not max minority seats, is not discriminatory. Failing to max minority seats does not automatically mean it's discriminatory. It would be interesting if there were any legislative history supporting the bolded bit of your statement, that " any policy, good or not, that had a discriminatory effect ... ." It would be further interesting to ascertain if the legislative history elucidated what "discriminatory" meant.

By that rationale, down the road, maybe to elect a black in the Cleveland area, a CD needs to go  to the black neighborhoods of both Akron and Canton (or Youngstown), in a long twisted snake. Is that what you think the VRA means, short of such an interpretation being an Unconstitutional racial gerrymander (which would only obtain if the lines did not have a partisan effect, which alas it would, so it actually would be Constitutional)?  How about a CD in Upstate NY that connects the black neighborhoods of Buffalo, Rochester, and Syracuse, if it got the number up to 50% BVAP? Sure, NY may have its "fair" share of black Congresspersons already, but Ohio would not if it had no black in Congress at all, and even just one is probably short changing them.

Take a look at the map below. Assume that the BVAP were 50% (it might get there by 2020, since the black population of Indianapolis is growing robustly). Further assume that the two black nodes are connected by a corridor running down the middle of I-65. The drawing of this CD has a partisan purpose (it gets rid of a Dem Congressperson, or at least makes one of the two Dem seats marginal), so it's Constitutional. Must this seat be drawn under your interpretation of the VRA? If not, why not? I mean, there is no contiguity threshold in the VRA explicitly set out either, is there?  Assume the Congressperson from Indianapolis is not black, so we don't have that distraction.



Lawyers just love pushing hypotheticals to the extreme. That's why we make the big bucks.

[muon2]

Than any lines, no matter how gross, under that interpretation, that do not max minority seats, would be deemed to have a discriminatory effect. I doubt SCOTUS would interpret the statute as amended as abandoning any semblance of a balancing test. Nor do I think any court has demanded gross lines. Rather, I think the courts would find any approach that is grounded on good public policy, even if it does not max minority seats, is not discriminatory. Failing to max minority seats does not automatically mean it's discriminatory. It would be interesting if there were any legislative history supporting the bolded bit of your statement, that " any policy, good or not, that had a discriminatory effect ... ." It would be further interesting to ascertain if the legislative history elucidated what "discriminatory" meant.

I don't know if I've made my references clear, since I'm not trying to support the line I have bolded above. Congress has said that the effect of districting methods, not just intent, cannot deny minorities fair opportunity, and that was said specifically to address a situation of neutral districting as identified by SCOTUS. SCOTUS has clearly said that nothing compels one to max out minority seats, as maximum is not the same as fair opportunity. SCOTUS has said that rough proportionality is a factor to consider to show that there is fair opportunity.

My conclusion is that if there is significantly less than rough proportionality then it is more likely this will be the subject of a federal section 2 claim. Based on Congress' 1982 amendment of the VRA one can't have neutral districting completely trump the VRA. Plaintiffs will show that the state's plan has a measurable effect on minority participation. Plaintiffs will show a map with modest accommodations from the strict rules to show that a plan can both substantially comply with neutral districting and provide fair opportunity for minorities. That's basically how I approached my version of south Cook above reposted below. Other than possibly my SD 6 is there any of the black districts (1-8) that are particularly bad from a neutral mapping perspective? We can debate if plaintiffs would prevail, but isn't that the sort of balancing test you would advocate?

[Torie]

"Plaintiffs will show a map with modest accommodations from the strict rules to show that a plan can both substantially comply with neutral districting and provide fair opportunity for minorities."

Well, we are making progress now. We are now down to what "modest" means, a word also not in the statute, but rather made up by you. See how speculative this all is?  But I get where you are going, which as you say, is getting into the balancing test zone area, which is were SCOTUS mostly lives. So we find some common ground - at last!  

Anyway, in that spirit, I would say, "modest" means, the metrics of doing the balancing test means,  choosing the plan out of those available following neutral redistricting principles, that gets minorities closest to proportionality. Pick the chops that do that out of the array of possibilities. Yes, cheat a bit on erosity if the contiguous minority zone is erose to the extent necessary. That gets the process out of the loosey goosey, wholly subjective, I know what's modest when I see it approach. I would just be amazed if SCOTUS ruled otherwise, simply because Congress went the "effect" route to get rid of at large voting. Requiring maps to follow good government principles, and not sacrifice that loadstar, merely in order to get closer to proportionality, is just not discriminatory.

Non good government maps that suddenly become good government when it comes to minority districts, thereby reducing their number, would be discriminatory. Consistency here is key. So in Illinois, where the idea of good government maps is subversive and un-American, your map may well be VRA required. It's probably less erose and choppy  than the existing map. There is no good government metric in play to defend. If you are in the business of drawing those erose messes to elect white Democrats to Congress downstate, you had better be equally messy when it comes to generating minority CD's. Anything less, is well, yes, you guessed it, "discriminatory!"

[muon2]

Well of course it's all about what is reasonable.

SD 1 (51.9% BVAP) and 2 (55.0%) follows township and muni lines
SD 3 (65.7%) stays within Chicago and goes north to include all of Hyde Park.
SD 4 (66.5%) and 5 (75.9%) were pulled west following political boundaries, main roads and railroads and maintain compact shapes.
SD 6 (59.9%) is squeezed by the lake and the need to create districts with HVAP sufficient to elect candidates of choice. It also keeps Chinatown intact in SD 9. The court has said in the case of IL CD-4 that unusual shapes can be justified to comply with the needs of two different minority groups.
SD 7 (53.2%) follows rail lines, highways and the L, and stays within Chicago. The chop to the north encompasses the whole neighborhoods of River West and Goose Island. The chop into the Austin neighborhood to the west is required to equalize population with SD 8.
SD 8 (57.9%) follows muni lines to the west of Chicago and is constrained on the north by Latino SDs.

Is that a modest accommodation from neutral principles and more reasonable than providing only 6 black majority SDs, which is demonstrably less than rough proportionality?

This is more than a hypothetical exercise. There is a petition drive under way in IL to go to a redistricting commission and respecting political boundaries is a component. In response there is an active campaign to discredit the petition drive primarily by suggesting that minorities will be disenfranchised though these neutral principles.

[Torie]

I assume you are asking this assuming the Muon2 statute is adopted in Illinois. Again, one needs a more objective standard of what is "modest." Maybe it's elastic depending on far one gets from proportionality, and maybe not. And is the proportional test based on population percentages within just the metro area, or statewide, for this purpose (so one needs a disproportionate number of black districts, to make up for blacks being elsewhere, but too thin on the ground to generate a district). How many minority districts do you lose, by following your metrics (with some cheat room for erosity, particularly to deal with competing minority zone "wall" issues)?  Of course, with black districts, one needs to decide what BVAP you need to elect a black.

[ElectionsGuy]

Northern California:



6: 75.2% Obama, 24.8% McCain = Safe D
11: 53.7% McCain, 46.3% Obama = Safe R
12: 61.0% Obama, 39.0% McCain = Safe D
14: 54.3% McCain, 45.7% Obama = Safe R

Bay Area Close-Up:



1: 85.1% Obama, 14.9% McCain = Safe D
2: 74.2% Obama, 25.8% McCain = Safe D
3: 70.6% Obama, 29.4% McCain = Safe D
4: 73.1% Obama, 26.9% McCain = Safe D
5: 87.1% Obama, 12.9% McCain = Safe D
9: 70.8% Obama, 29.2% McCain = Safe D
10: 64.4% Obama, 35.6% McCain = Safe D

Sacramento Close-Up:



7: 69.9% Obama, 30.1% McCain = Safe D
8: 52.6% McCain, 47.4% Obama = Likely R

Central Valley:



13: 57.4% Obama, 42.6% McCain = Likely D
15: 52.4% Obama, 47.6% McCain = Lean D
33: 56.0% McCain, 44.0% Obama = Safe R
35: 58.2% McCain, 41.8% Obama = Safe R

Southern California:



34: 50.5% Obama, 49.5% McCain = Toss-Up
37: 55.9% McCain, 44.1% Obama = Safe R
39: 55.0% Obama, 45.0% McCain = Likely D

Los Angeles Close-Up:



16: 67.8% Obama, 32.2% McCain = Safe D
17: 64.6% Obama, 35.4% McCain = Safe D
18: 81.2% Obama, 18.8% McCain = Safe D
19: 70.4% Obama, 29.6% McCain = Safe D
20: 81.0% Obama, 19.0% McCain = Safe D
21: 90.7% Obama, 9.3% McCain = Safe D
22: 66.9% Obama, 33.1% McCain = Safe D
23: 76.1% Obama, 23.9% McCain = Safe D
24: 59.3% Obama, 40.7% McCain = Safe D
25: 63.8% Obama, 36.2% McCain = Safe D
26: 59.0% Obama, 41.0% McCain = Safe D
27: 54.6% McCain, 45.4% Obama = Safe R
28: 53.1% McCain, 46.9% Obama = Likely R
29: 67.5% Obama, 32.5% McCain = Safe D
30: 53.0% Obama, 47.0% McCain = Lean D
32: 59.3% Obama, 40.7% McCain = Safe D
38: 56.0% McCain, 44.0% Obama = Safe R
40: 51.8% McCain, 48.2% Obama = Likely R

San Diego Close-Up:



31: 69.0% Obama, 31.0% McCain = Safe D
36: 56.7% Obama, 43.3% McCain = Likely D

29.5/40 = 73.8% D. The current makeup is 25-14 D.

[ElectionsGuy]

State Senates:

[jimrtex]

At large voting is very different, because with polarized voting, it is a recipe for shutting out the minority entirely. And there is no good policy reason for it. There is a good policy reason for neutral line drawing, and the cases where it screws the minority will be rare, and even then, only at the margins when it comes to proportionality.

In Mobile, the city commission exercised both executive and legislative authority. It was replaced by a mayor-city council system.

I think a reasonable VRA case can be made in Hudson, because of its multi-member districts. The ward with the greatest black population is oversized, and it splits a census block with a large concentration of blacks. It's not going to matter that boundary was set 150 years ago.

[jimrtex]

Texas:

Houston Close-Up:



11: 74.4% Obama, 25.6% McCain = Safe D
12: 76.9% Obama, 23.1% McCain = Safe D
13: 59.8% Obama, 40.2% McCain = Likely D
14: 61.6% McCain, 38.4% Obama = Safe R
15: 72.5% McCain, 27.5% Obama = Safe R
16: 65.3% McCain, 34.7% Obama = Safe R
17: 65.6% McCain, 34.4% Obama = Safe R

You eliminated a Hispanic opportunity district.

[Torie]

At large voting is very different, because with polarized voting, it is a recipe for shutting out the minority entirely. And there is no good policy reason for it. There is a good policy reason for neutral line drawing, and the cases where it screws the minority will be rare, and even then, only at the margins when it comes to proportionality.

In Mobile, the city commission exercised both executive and legislative authority. It was replaced by a mayor-city council system.

I think a reasonable VRA case can be made in Hudson, because of its multi-member districts. The ward with the greatest black population is oversized, and it splits a census block with a large concentration of blacks. It's not going to matter that boundary was set 150 years ago.

There is no way to draw a 50% BVAP ward. In fact, I don't recall a single census block that was 50% BVAP. So no, the VRA is not subject to being triggered.

[jimrtex]

At large voting is very different, because with polarized voting, it is a recipe for shutting out the minority entirely. And there is no good policy reason for it. There is a good policy reason for neutral line drawing, and the cases where it screws the minority will be rare, and even then, only at the margins when it comes to proportionality.

In Mobile, the city commission exercised both executive and legislative authority. It was replaced by a mayor-city council system.

I think a reasonable VRA case can be made in Hudson, because of its multi-member districts. The ward with the greatest black population is oversized, and it splits a census block with a large concentration of blacks. It's not going to matter that boundary was set 150 years ago.

There is no way to draw a 50% BVAP ward. In fact, I don't recall a single census block that was 50% BVAP. So no, the VRA is not subject to being triggered.

You only have to be able to draw a single aldermanic district (1/10 or 1/11) of the total population. Hudson is using an oversized multi-member district as a device to deny the right to vote.

[Torie]

At large voting is very different, because with polarized voting, it is a recipe for shutting out the minority entirely. And there is no good policy reason for it. There is a good policy reason for neutral line drawing, and the cases where it screws the minority will be rare, and even then, only at the margins when it comes to proportionality.

In Mobile, the city commission exercised both executive and legislative authority. It was replaced by a mayor-city council system.

I think a reasonable VRA case can be made in Hudson, because of its multi-member districts. The ward with the greatest black population is oversized, and it splits a census block with a large concentration of blacks. It's not going to matter that boundary was set 150 years ago.

There is no way to draw a 50% BVAP ward. In fact, I don't recall a single census block that was 50% BVAP. So no, the VRA is not subject to being triggered.

You only have to be able to draw a single aldermanic district (1/10 or 1/11) of the total population. Hudson is using an oversized multi-member district as a device to deny the right to vote.

I doubt it, but I would tend to doubt there is any case law about making districts smaller, as opposed to a typical number. Anyway, at the moment, there are 3 blacks and 1 Bangledeshi out of the 10 council members elected by district. So the representation is in fact reasonably proportional.

[jimrtex]

I think a reasonable VRA case can be made in Hudson, because of its multi-member districts. The ward with the greatest black population is oversized, and it splits a census block with a large concentration of blacks. It's not going to matter that boundary was set 150 years ago.

There is no way to draw a 50% BVAP ward. In fact, I don't recall a single census block that was 50% BVAP. So no, the VRA is not subject to being triggered.

You only have to be able to draw a single aldermanic district (1/10 or 1/11) of the total population. Hudson is using an oversized multi-member district as a device to deny the right to vote.

I doubt it, but I would tend to doubt there is any case law about making districts smaller, as opposed to a typical number. Anyway, at the moment, there are 3 blacks and 1 Bangledeshi out of the 10 council members elected by district. So the representation is in fact reasonably proportional.

Multi-member districts are no different than at-large elections.