William Schneider's essay in Opinion on reapportionment is refreshing in its candid admission that the Democrats have gerrymandered California to death. He is quite wrong, however, in his conclusion that the cure (court intervention) would be worse than the disease.
It is not necessary for the courts to involve themselves affirmatively in the reapportionment process in order to be able to recognize a clear abuse. In California, for example, the evidence is overwhelming and uncontested that the state's Democrats set out deliberately to disenfranchise Republican votes. You need only one look at the crazy lines on the California reapportionment maps, whose author the late Rep. Phillip Burton (D-San Francisco) boasted of them as "my contribution to modern art," to reach that conclusion.
Just as in Baker vs. Carr, the courts can set out simple, quantitative guidelines--e.g., districts not to cross county lines, whole cities to be included where possible, statewide representation to approximate average party voter turnout in recent elections--which are easily applied. Or the courts don't have to issue any guidelines at all. They can simply recognize a clear abuse and say to the Legislature, "do better." You need not draw a precise line to know that, wherever it is drawn, certain cases fall outside it.