Editing Gerrymandering (section)

===Germany===<!--I rewrote this paragraph. Somebody please review it.-->

Since [[Germany]] utilizes a [[proportional representation]] system, gerrymandering is rarely a problem. There is, however, one situation in which gerrymandering can affect an election. In Germany for a party to win any seat, it has to win at least 5% of the vote or three constituencies. This latter rule was applied most recently in the [[2021 German federal election|2021 federal election]], in which the [[The Left (Germany)|Left]] entered the [[Bundestag]] despite winning less than 5% of the vote.

In 2000 the electoral constituencies were redrawn and the PDS, which entered the Bundestag in the elections of 1994 and 1998 with this rule, accused the SPD, who were in power at the time of redrawing the constituencies, of gerrymandering them by breaking up districts in East Berlin, a PDS stronghold, and combining them with West Berlin. In the [[2002 German federal election|2002 federal election]] the PDS lost their third constituency and entered the Bundestag with only two seats. Had they won a third direct seat, they would have qualified for an additional 25 seats.

Another scenario in which gerrymandering can affect German federal election is when a party wins more constituencies than their overall share of the popular vote—those extra seats, called "[[Overhang seat|Überhangmandate]]", remain. In the [[2009 German federal election|Bundestag election of 2009]], [[Angela Merkel]]'s [[CDU/CSU]] gained 24 such extra seats, while no other party gained any;<ref name=":2">{{cite web |title=Overhang mandates – The Federal Returning Officer |url=https://www.bundeswahlleiter.de/en/service/glossar/u/ueberhangmandate.html |access-date=10 May 2020 |publisher=Statistisches Bundesamt}}</ref> this skewed the result so much that the [[Federal Constitutional Court of Germany]] issued two rulings declaring the existing election laws invalid and requiring the Bundestag to pass a new law limiting such extra seats to no more than 15. In 2013, Germany's Federal Constitutional Court ruled on the constitutionality of Überhangmandate. From then on each other party would receive seats as well to remedy the disproportion, thereby making it impossible to have disproportionate election results.