Brian Kalt, a law professor at Michigan State University, submitted a letter to the New York Times in response to the same editorial that Matthew Franck criticizes today on NRO. Kalt also sent me a copy:

You complained that a proposal to allocate California electoral votes by congressional district would make it “hard” for Democrats to be elected president even with “a sizable majority of the popular vote.” Your statement is ahistorical. Anyone who has won a sizable popular-vote majority has also won a comfortable electoral-vote majority. Moreover, every president who won the popular vote would still have won even if his biggest state had used district allocation. Such a switch would have changed two elections–2000 and 1876–when the victor lost the popular vote. Historically, then, the only effect would have been to help popular-vote winners. The California proposal might be cynical and opportunistic, but for you to say that it would “rig elections” and badly handicap Democrats “no matter how the popular vote comes out” is quite a stretch.

Kalt also points out that it has been more than 40 years since the Democrats won a sizable majority of the popular vote.