The translation of citizen votes into legislative seats is of central importance in democratic electoral systems. It has been a longstanding concern among scholars in political science and in numerous other disciplines. Through this literature, two fundamental tenets of democratic theory, partisan bias and democratic representation, have often been confused. We develop a general statistical model of the relationship between votes and seats and separate these two important concepts theoretically and empirically. In so doing, we also solve several methodological problems with the study of seats, votes and the cube law. An application to U.S. congressional districts provides estimates of bias and representation for each state and deomonstrates the model’s utility. Results of this application show distinct types of representation coexisting in U.S. states. Although most states have small partisan biases, there are some with a substantial degree of bias.