The Pennsylvania plan would've certainly been struck down by courts because it allotted the two at-large EVs based on who won the majority of the districts, not the statewide vote.
Yeah, violating the "non-equal population" part of
Gray v. Sanders, right? (Congressional districts within a state have approximately equal population as of the last census unlike Georgia's counties divided by their unit vote under their system, but you'd still be electing a pair of individual electors under a unit system, an "electoral college" to elect those two electors.)
