Affidavit of Arnold L. Brown

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Matter
- Gingles
Case
- Thornburg v. Gingles
U.S. state
- North Carolina
Collection
- Case Files
Taxonomy
Identifier
- 2ee4ccb4-d592-ee11-be37-00224827e97b

Cite this item

Case Files, Thornburg v. Gingles Hardbacks, Briefs, and Trial Transcript. Affidavit of Arnold L. Brown, 1984. 2ee4ccb4-d592-ee11-be37-00224827e97b. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/1803e444-255c-41fd-9979-bb42a6609f46/affidavit-of-arnold-l-brown. Accessed December 03, 2025.

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    .t EXHTBTT 86

toursE r. rAwsoN
SUPENVISOR

PHONE 459-414t
EXT. 4la

ARNOLD L. BROWN, Choirmon

R. QUILLEN WARD, SecrelorY

T. E. RICKS. Member

NASH COUNTY BOARD OF ELECTIONS
P. O. BOX 305

NASHVILLE, NORTH CAROLINA 27856

AFFIDAVIT

NORTH CAROLINA
NASH COUNTY

Arno'ld L. Brown, being first duly sworn, deposes and says:

That I am a Citizen and resident of Nash County, Middlesex, North
Carol i na;

That I am the Chairman of the Nash County Board of Elections and
have served in that capacity for several years;

That it has been brought to my attention that a request has been made

to have the .l984 North Carolina House of Representatives Primary on November
6,'1984 along with Wilson and Edgecombe Counties. That if such a request is
approved by the appropriate authorities, it would cause a substantial hardship
to all counties involved, and certainly to Nash County;

That numerous disadvantages would be experienced and some of these
disadvantages would be, as follows:

(f) Unless the North Caro'lina General Assembly has previously
authorized the State Board of Etections to make modifications to the existing
election laws, there could be a legal question as to whether or not such a

primary election could take p'lace on November 6,1984, the date of the General
El ecti on.(2) That many citizens of Nash, lrlilson and Edgecombe Counties who could
be potential candidates would not have had an opportunity to make an appropri-
ate evaluation in being a candidate. These candidates would not know the
boundaries of the distiict or peop'le within the district. There would be
insufficient time for appropriate organization, etc.

(3) Such a brief time would be extremely unfair to a candidate who

was not is-well known in the district in question since he or she wou'ld not
have the opportunity of organizing an appropriate campaign in such a short
time frame.(4) The appropriate Boards of Election would have substantial diffi-
cu'lty in'd6terminihb d'istrict lines in a precise manner and in being assured
that all potential voters would be voting in the appropriate districts. This
would be bspecial'ly difficult if the Districts were not set off by Township
or Precinct'lines.- A further difficulty wou'ld be the fact that Nash County
has approximately 34,000 registered voters and dividing this number into appro-
priatb'districts wou'ld be a substantia'l undertaking in this short period of
time.



Page two
Affidavit of Arnold L. Brown

(5) Unless the General Assemb'ly has authorized the State Board of
Elections to modiiy the laws relative t-o absentee ballots, sqq! an election
;ilia veiy we1t Uj iif egai. 

- 
Further,_assuming that such modification would

u6-i.gii,"tti; .pp.op.ii[E goa.ds ot gtection have previously mai]ed appli-
iatiois ind balibts, as provided by 1aw, to potential voters and this
iiitrilv-rouia hive'to bb re-administered. In addition, the Nash County-
goird o? ri..iioni-woutd be requiied to cause additional_printing of ballots
to be made. One ottrei difficuity regarding absentee ballots would be the
fact that nrrerori p."ronr have 

-previously-requested absentee bal'lots by

i'u.ilng-ihe-;;Geneiai 
-Eiection" citegory i-n.tne app]icationr lince no one

rea'lized that th;;; .oria poislbly 5e i primary,.the election's office wou'ld

not be authorized to forward Housl of Reilresenlative ballots since it would

not Ue a ,'Generai ii".ilon" but would be'a "Primary". .t'lou'ld this not be an

uaa.a prob'lem which could very we'll be unfair to candidates and voters?

The statements as Iisted above are only a few reasons that would

cause difficulty-io the Nash County Board of Elections, and likely to the

Edgecombe and l'lllson County Boards of E'lection'

If the House of Representatives Primary was to occur at the November

6,'1984 General ii.ition, i be]ieve that very few peop]q'.lf 1ny' would

u.n.iit. -A prtmiri-neid at a moie detiberat! time would be of substantia'l
benefit to oirr votLrs, candidates and elections office'

Respectfully submitted this the 24th day of September' '1984'

NASH COUNTY BOARD OF ELECTIONS

A
U,,._,,O ZZ.o=..__

Sworn to and subscribed before me this 24th day of September' 1984'

My commission exPires: tf87

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Affidavit of Arnold L. Brown

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Cite this item

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