Derek Muller: “State legislatures have modified the rules for the selection of presidential electors when they worry that the people of the state will vote for a disfavored candidate. In 1892, for instance, Democrats gained control of the Michigan legislature. They decided that presidential electors should be appointed according to popular vote totals in each congressional district, as opposed to the statewide winner-take-all system that had previously existed. Michiganders had consistently voted for a slate of Republican electors in the recent past, and the move to elections by district guaranteed that Democrats would win at least a few of electoral votes.”
“In McPherson v. Blacker, the Supreme Court approved Michigan’s move and found that the mode of appointing electors was ‘exclusively’ reserved to the states. The Court would not interfere with the state legislature’s decision, whatever the reason.”
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