 The issues of race-conscious electoral districting and descriptive racial representation have also garnered substantial attention. Race-conscious districting is the practice of drawing geographically based electoral districts in which the majority of voters are Black. Descriptive racial representation holds that Black populations are best represented by Black politicians. Iris Marion Young (1990, 183–191) provides a spirited defense of descriptive representation for racial minorities, grounded in their experiences of “oppression, the institutional constraint on self-determination”, and domination “the institutional constraint on self-determination” (1990, 37). Anne Phillips (1995) furthers this position, arguing that representatives who are members of minority racial groups can enhance legislative deliberation. Melissa Williams (1998) also defends the deliberative contribution of descriptive racial representation, but adds that minority constituents are more likely to trust minority representatives, since both will be affected by laws that overtly or covertly discriminate against minority racial groups. Finally, Jane Mansbridge (1999) carefully demonstrates why a critical mass of minority representatives is needed, in order to adequately advocate for common minority interests as well as to convey the internal diversity within the group. In a later work, Young (2000) addresses critics who argue that descriptive representation relies upon group essentialism, since members of a racial group need not all share the same interests or opinions. In response, Young suggests that members of the same racial group do share the same “social perspective” grounded in common experiences, similar to the interactive kind variant of racial constructivism discussed earlier. But because it is unclear that Black individuals are more likely to share common experiences than common interests or opinions, Michael James prioritizes using race-conscious districting to create Black racial constituencies which can hold Black or non-Black representatives accountable to Black interests (James 2011). Abigail Thernstrom (1987) condemns race-conscious districting for violating the original principles behind the 1965 Voting Rights Act and the 15th Amendment, by promoting the election of black representatives rather than simply guaranteeing black voters the right to cast ballots. J. Morgan Kousser (1999) responds that race-conscious districting simply reflects the right to cast a “meaningful” vote, as implied by the 15th Amendment protection against not only the denial but also the “abridgment” of the right to vote. Lani Guinier (1994) compellingly suggests that instead of drawing majority black districts, we should adopt more proportional electoral system that facilitate the electoral strength of racial and other minorities. Michael James (2004) suggests that alternative electoral systems facilitate not only descriptive racial representation but also democratic deliberation across racial lines.