Fourth Circuit affirms dismissal of complaint about bizarrely-drawn Congressional district

In Duckworth v. State Administration Board of Election Laws, the Fourth Circuit in an opinion in an opinion by Judge Luttig joined by Judge Michael and District Court Judge Goodwin affirmed the dismissal of a claim about the bizarre shape of a new Congressional district in Maryland, concluding that the district court's reasoning was wrong but the outcome was right because the pleadings failed to sufficiently state the second element of a political gerrymandering claim, "actual discriminatory effect."