Reapportionment of representatives between the states every ten years based on new census figures is required by Article I, Section 2 of the U.S. Constitution and Section 2 of the Fourteenth Amendment.[1] The Constitution, Supreme Court jurisprudence and federal law allow significant latitude to the individual states to draw their congressional and legislative districts as they see fit, as long as each district contains roughly equivalent numbers of people (see Baker v. Carr, Wesberry v. Sanders, and Reynolds v. Sims) and provides for minority representation pursuant to the Voting Rights Act. While control over redrawing district lines has been in the hands of state legislators for most of American history, a number of states, though not Arkansas, have adopted independent or bipartisan commissions for redistricting purposes in the last twenty years.