David Daley for The Atlantic:

In 2019, writing the decision for Common Cause v. Rucho, Chief Justice John Roberts closed off the federal courts as an avenue for addressing partisan gerrymandering. But, Roberts insisted, the Supreme Court’s decision did not condone these excesses. Rather, another path for addressing structural electoral reform existed. Noting the success of several citizen-driven state-constitutional amendments passed by ballot in Colorado, Michigan, and Missouri the previous November, Roberts said that citizens still had the tools to make change.

Just over a year later, however, that hasn’t proved to be the case.

Voters in Arkansas, North Dakota, and Idaho took Roberts up on his suggestion to drive reform via citizen-led initiative or by amending their state constitution. In Arkansas, with two different amendments, citizens worked to establish an independent redistricting commission and also open primaries and institute ranked-choice voting. In North Dakota, they looked to strengthen overseas-military voting and election audits, open primaries to all voters, and enact instant runoffs. Idaho voters, meanwhile, sought to expand funding for public education. One by one, these initiatives have been knocked off the ballots this summer by state and federal courts, and for the most tendentious and technical reasons.