I still think there's a misinterpretation of "recess" vis-a-vis "session". Sessions should be divided by recesses by definition, meaning that if congress recesses in summer, then the spring and fall of that year should be in different sessions. Otherwise, why does Article II, Section 2, say that a recess appointment expires at the end of the next session? Yet in actual practice each year is treated as one session regardless of how many recesses there are.

In 2004, when Republicans in Texas and Colorado wanted to redistrict for the second time after one census, it failed in Colorado due to a provision in the state constitution that says the redistricting is done only in consequence of the census. The effort in Texas succeeded despite a "Wisconsin filibuster", because there is no such implication in the Texas constitution.

Someone needs to peruse the Virginia constitution for anything we can use in court to reverse the re-redistricting there. And it needs to be done well before the election of 2014.