voters to calibrate the minority’s ability to elect its candidate in a multi-member district, we see no reason to use a quantity less than a numerical majority as the determinant in a single-member district. See Hastert v. State Bd. of Elections, 777 F. Supp. 634, 654 (N.D. Ill. 1991) (three-judge panel) (“The concerns animating the Gingles electoral majority precondition for multi-member cases — concerns of proof and relief — reside equally in the single-member context.”). Although the United States Supreme Court has left open this issue, the majority of federal circuit courts confronting the question have concluded that, when a district must be created pursuant to Section 2, it must be a majority-minority district. See, e.g., Hall v. Virginia, 385 F.3d 421, 423 (4th Cir. 2004) (<HOLDING>), cert. denied, 544 U.S. 961, 161 L. Ed. 2d 602
holding that the public harm requirement applies to fraudulent inducement claims because the fraud claims arise from related contract claims holding that the use requirement exists for  proposed state law claims and is analyzed in the same manner as under the federal claims holding gingles establishes a numerical majority requirement for all section 2 claims holding that section 890041 is not a jurisdictional requirement rather a requirement to maintain suit holding that exhaustion requirement applies to excessive force claims