<P> In 1789, at - large popular vote, the winner - take - all method, began with Pennsylvania and Maryland; Virginia and Delaware used a district plan by popular vote, and in the five other states participating in the election (Connecticut, Georgia, Maryland, New Hampshire New Jersey and South Carolina), state legislatures chose . By 1800, Virginia and Rhode Island voted at - large, Kentucky, Maryland and North Carolina voted popularly by district, and eleven states voted by state legislature . Beginning in 1804 there was a definite trend towards the winner - take - all system for statewide popular vote . </P> <P> States using their state legislature to choose presidential electors have included fourteen states from all regions of the country . By 1832, only South Carolina used the state legislature, and it abandoned the method after 1860 . States using popular vote by district have included ten states from all regions of the country . By 1832 there was only Maryland, and from 1836 district plans fell out of use until the 20th century, though Michigan used a district plan for 1892 only . </P> <P> Since 1836, statewide, winner - take - all popular voting for electors has been the almost universal practice . As of 2016, Maine (from 1972) and Nebraska (from 1996) use the district plan, with two at - large electors assigned to support the winner of the statewide popular vote . </P> <P> Section 2 of the Fourteenth Amendment allows for a state's representation in the House of Representatives to be reduced if a state unconstitutionally denies people the right to vote . The reduction is in keeping with the proportion of people denied a vote . This amendment refers to "the right to vote at any election for the choice of electors for President and Vice President of the United States," among other elections, the only place in the Constitution mentioning electors being selected by popular vote . </P>

When was the last time the electoral college was updated