Legal standards to determine when a single-member district plan constitutes a racial gerrymander in violation of the Voting Rights Act (or the U.S. Constitution) are not as well developed as are the standards for dilution involving multimember districts and at-large elections. This is in large part because there have been far fewer cases involving challenges to single-member district plans. Moreover, except for the legislative districts in New York whose redrawing was the subject of a challenge to the Justice Department's discretionary authority under Section 5 of the Voting Rights Act and for the congressional seats in the Dallas area that were redrawn by a federal district court in remedying a Fourteenth Amendment violation, no single-member district plan challenged as a racial gerrymander has been the subject of other than a per curiam opinion of the Supreme Court, and neither of these cases postdates Gingles. Indeed, since Gingles was decided in 1986, as of mid–1991 only a handful of Section 2 cases involving challenges to single-member districts had been decided, and only four of these had been reviewed at the appellate level.

Despite this lack of activity to date, single-member district issues and related matters will rise to the fore in the 1990s. For one thing, the number of challenges to at-large or multimember district systems is likely to fall, as a large number of the relevant jurisdictions have already been successfully challenged (see the state-by-state summaries in Davidson and Grofman, 1992), and many of the remaining jurisdictions are likely to adopt single-member districts rather than incur the costs of a voting rights lawsuit in which they are unlikely to prevail.