Fax to Cox from Carraway RE: Edited Joint Appendix
Correspondence
July 26, 2000
50 pages
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Case Files, Cromartie Hardbacks. Fax to Cox from Carraway RE: Edited Joint Appendix, 2000. 4518b3b1-dd0e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/19048786-8661-4b7e-8cbd-b4f699d1ece8/fax-to-cox-from-carraway-re-edited-joint-appendix. Accessed November 23, 2025.
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State of North Carolina
Department of Justice
: P. O. Box 629
MICHAEL F. EASLEY RALEIGH
ATTORNEY GENERAL 27602-0629
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10°d 80:01 100. ef In £9.9912676: ed 117 WIJ3dS 99 ON
[caption omitted for printing]
DECLARATION OF DR. RONALD F. WEBER
I,"Ronald E. Weber, BPh.D., declare pursuant to 28 U.S.C.
1746 as follows:
1. I am currently the Wilder Crane Professor of Government
in the Department of Political Science at the University of
Wisconsin, Milwaukee, Wisconsin; President of Campaign and
Opinion Research Analysts, Inc.; former co-editor of The Journal
Qf Politics and Chairman of the Department of Political Science
at the University of Wisconsin, Milwaukee; former Fulbright
Commission John Marshall Professor of Political Science at the
Budapest University of Economic Sciences and the Central European
University, Budapest, Hungary (1996-97); and former President of
the Southern Political Science Association (1997-98). I received
my B.A. in Political Science and History from Macalester College,
St. Paul, MN, . in 1964 and a Ph.D. in Political Science from
Syracuse University in 1969, with specialties in American state
politics, voting behavior, and quantitative analyses of political
data. A copy of my curriculum vitae is attached as Exhibit A.
* ok
3. I have been retained as a consultant and expert witness
in a number of redistricting and voting rights cases and have
¢0'd 80:01 (QQ. oC I[ 9.991616: Xe ER ol
been qualified as an expert by the U.S. District Courts in [22
instances] . . . I have testified in a number of Congressional
and state legislative redistricting cases . .'. . 1 also have
extensive experience developing redistricting plans for local and
state government clients and assisting them with preclearance of
those plans under Section 5 of the U.S. Voting Rights Act of
1965, as amended in 1982.
I address the following questions
(1) whether race was the predominant factor used by the
state of North Carolina to draw the boundaries of the
1297 U.S. Congressional districts:
(2) whether the state of North Carolina in creating the
U.S. Congressional ‘districting plan of 1997
subordinated traditional race-neutral districting
principles, such as compactness, contiguity, respect
for political subdivisions or communities defined by
actual shared interests, to racial considerations;
woo
(5) whether African-American voters residing in
Districts il and 12 inithe Act 588 plan of 1997
participate at lower rates than white voters in recent
state-wide elections, indicating some evidence that a
11 WIZ48 5H
history of official discrimination has led to
politically significant differences in political
participation in the districts as drawn in 1997;
(6) whether sufficient levels of white crossover voting
ex1sts in the northeast and Piedmont regions of North
Carolina such that fair U.S. Congressional districts
can be drawn that do not need to be majority African-
American in voting age population or voter registration
in order to allow African-American voters a reasonable
opportunity to elect candidates of choice in U.S.
Congressional elections; and
(7) whether race-predominant U.S. Congressional
Districts 1 and 12 in the 1997 North Carolina plan are
overly safe from the standpoint of giving a candidate
of choice of African-American voters an opportunity to
be elected, thus questioning whether the plan was
narrowly tailored to satisfy a compelling state
interest.
€. The results of my analysis to date will be presented in
this declaration in the following form: in Section I, I will
outline briefly the history of Congressional districting in North
Carolina since 1960; in section II, I will describe the analyses
conducted to answer the first two questions and set forth my
70d 60.01 00. C17 $929912616: Xe LI Wide od iy
conclusions on those questions; . . . and in section V, VI, and
VII, I will discuss participation rates of African-American and
white voters as well as white crossover rates in recent statewide
elections within two regions of North Carolina and the electoral
safeness of North Carolina Congressional districts 1 and 12.
Tables, charts, and exhibits relevant tc my analyses will be
included within the body of the declaration or as attachments to
this declaration.
I. HISTORY OF RECENT CONGRESSIONAL REDISTRICTINGS
IN NORTH CAROLINA
10. As was true following the 1370 Census of Fopulation,
the 1980 Census of Population revealed that the 11 districts of
the 1970s were out of population balance. Thus, the North
Carolina General Assembly had to adjust the populations of the 11
SU °d 6:07 - 00, S21 $949912616: Xe 4 117 WITS 9d ON
districts before the 1982 elections. The first plan adopted in
July, 1981 did not receive pre-clearance under Section 5 by the
U.S. Department of Justice. The General Assembly followed-up
with a revised plan that satisfied the Department of Justice’s
objections in a special session of February, 1982. " For the first
time in the modern history of North Carolina, it was necessary to
split four counties in order to balance the populations across
the districes, Avery, Johnston, Moore, and Yadkin counties were
each split across two districts. The town of Chapel Hill as well
as the city of High Point were each split across two districts
owing to the fact that those two places cross county lines and
the General Assembly decided to draw the Congressional districts
using county lines between Orange and Durham counties and between
Guilford and Randolph counties. These 11 districts were used in
the elections of 1982-1990.
12
L5, I conclude this section by making several observations.
First, the sub-dividing of counties to achieve equally populated
Congressional districts in North Carolina is a relatively recent
occurrence, taking place for the first time with the splitting of
Just four counties in the early 1980s. Second, no county in
North Carolina is large enough that it must of necessity be sub-
divided to comply with the principle of "one-person, one-vote”.
Mecklenburg County, the largest county in population in North
90 'd BO: 0% 0, BT TL $9991L616: xe 117 T1348 23 OH
Carolina, is slightly smaller than a current Congressional
district. Third, . . . at the maximum a total of eleven North
Carolina counties might need to be split to create an equally
populous twelve district plan, by using whole counties to create
Congressional districts and then splitting just one county to
balance the population between each of two districts. Fourth,
the percentage of African-American persons in the North
Carolina population declined between 1980 and 1990.
Finally, as I will consistently point out below, the appropriate
social science benchmark for comparison of the challenged plan is
the plan ¢f the 1980s (with 11 districts) and not the
constitutionally invalidated 12 district plan of the 1990s.
LL. ANALYSIS OF DISTRIGCTING CRITERIA FMPLOYED BY STATE
14. The question of whether race was the predominant factor
used by the state of North Carolina to draw the boundaries of the
U.S. Congressional districts in 1997 can be addressed by an
examination of both tabular data prepared by the North Carolina
Information Systems Division from data compiled by the U.S.
Bureau of the Census and maps created on the computer facilities
of the North Carolina General Assembly Legislative Services
Office Redistricting System. Data from both sources are reported
20°d BOOT 00. wir 9.991.616: x84 117 W1J345 ad IN A A
in tabular form and on maps to display the use of race as a
redistricting criterion.
15. . . . . Table 1 reports for each 1997 North Carolina
Congressional district the racial composition of the total
population of the counties that were sub-divided in the creation
of the plan using data from the County Split Assignments Report
of March 26, 1997 of the North Carolina Information Systems
Division. For both Districts 1 and 12 that were created to elect
an African-American member of Congress, the county splits show a
typical pattern of African-American total population majorities
in the largest jurisdictions of each district.
LIA 34S ad ON
TABLE 1
Prepeoxtion of Total Populaticn in Spllt Counties
by Congressional District for 1997 Flan (HB 586--Plan A)
(abridged)
African-
County /City cD Total White 2 auer.
Forsyth 5 206,766 181,381 87.1 22,297 11.1
Davidscn e 59,003 57,135 65.2 2,468 4.1
Guilford 6 211,363 186,33) "83.2 21,541": 10.2
Rowan 6 77,499 70,819 91.4 5,979 2.3
Mecklenburg 8 282,808 264,604 90.4 21,0286 7:2
Iredell 10 54,472 48,438 B&.9S Ne 526. 10.3
Davidson 12 66, 684 26,161 384.2 0,846 14.8
Forsyth 12 59,112 15,537 «25.3 43,105 172.9
Guilford 2 13¢,057 63,253 45.5 90,114: 81.5
Iredell 12 38,459 28,769 74.8 9,343 24.3
Mecklenburg 12 218,625 | 100,047) 45.9% 113,442 51.9
Rowan 12 33,106 21,032 "e3.% 11,754 35.6
8
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nm 4a Woh aan as te
* x x
17. Turning next to District 12, the racial make-up of the
parts of the six sub-divided counties assigned to District 12
include three with parts over 50 percent African-American and
three in which the African-American percentage is under 50
percent. Almost 75 percent of the total population in District
12 comes from the three county parts which are majority African-
American in population. Mecklenburg, Forsyth, and Guilford
counties which contribute almost 75 percent of the district’s
total population are located at the extremes of the district.
The other three county parts (Davidson, Iredell, and Rowan) have
narrow corridors which were designed to pick up as many African-
American persons from each of those counties to fill out the
district to an ideal sized district. A precinct level map of
District 12 shows that all African-American majority precincts
but one in those three counties have been assigned to the
district. Conversely, Table 1 reports that the African-American
percentage of the total population in the parts of those split
counties assigned to another district than District 12 is
consistently lower. For example, the part of Mecklenburg County
assigned to District 9 is 7.2 percent African-American in total
population, while the part of Forsyth County allocated to
District 5 is 1l.1 percent African-American in total population
and the part of Guilford County assigned to District 6 is 10.2
01d 80:01 a0, 22.170 2949912616: ~& 117 HIT Si ON
percent African-American. The county splits as they impact the
white majority districts adjacent to District 12 in the Piedmont
are those county splits for the districts where the intent
usually was to carve out African-American voters so as not to
endanger the electoral bases of the candidates who might not be
characterized as candidates of choice of minority voters (e.g.
Districts 5, 6, and 9). Almost every time there was an
opportunity to use race as the basis for dividing political
subdivisions up politically, the North Carolina Congressional
districting plan does it in the Piedmont part of the state as
well.
18. ‘Table 2 provides further confirmation that race was the
predominant factor in the drawing of the lines for the North
Carolina Congressional districts in 1997. This table reports the
exact same data as in Table 1 except that in Table 2 the data are
organized by county rather than Congressional district.
When counties were split to achieve population equality, the
racial composition of the components differ little. When the
splits are for racial purposes, the differences are large.
10
11d 60:0 QO. 9 Nf $9.9912616: <&4 117 W345. 50
proportion or Tetald Population in Split Counties
by County for 19897 Congressional Districting Plan (HB 586--Plan A)
[abridged]
African-
ik 032) Total White kd Amer, 3
Davidson 6 59,9932 57,135+905.2 2,468 4.1
Davidson 12 66, 684 56,161 B4.2 0,846 14.8
Forsyth : 206,768 181,381 "817.7 22.987 231.1
Forsyth 12 59,132 15,5837 26.3 43,105 "72.9
Guilford 6 211.363 "385,331 88.2 21,541 0.2
Guilford 12 136,057 $3,253 48.5 70,334. - 2%.5%
Iredell 10 54,472 48,438 88.9 S$, 526 10.1
Iredell 12 38,459 28,769 74.8 9,343 24.3
Mecklenburg g 292,808 264,604 90.3% 21,026 SR
Mecklenburg 12 238,825 "i100,047 45.9 113,442 51.8%
Rowan 6 77,498 70,819 91.4 5,979 7.7
Rowan 12 23,106 21,032 :63.% 11,794 25%.6
1:
ZT °d 60:01 00. oC INL £9.991070: xe 4 LIN HI Eds 94 ON
39. The pattern shown in each of the six counties that are
split between District 12 and an adjacent district is one in
which most of the time the sub-division was along racial lines.
All six counties were split aleng racial lines. The most
dramatic examples from Table 2 include Forsyth County where 72.9
percent ¢f the total population allocated to District 12 is
African-American while only 11.1 percent of the total population
assigned to District 5 is African-American, and Mecklenburg
County where 51.9 percent of the total population allocated to
Pistrict 12 is African-American while only 7.2 percent of the
total population assigned to District 9 is African-American.
Similarly, I find Guilford County where 51.5 percent of the total
population allocated to District 12 is African-American while
only 10.2 percent of the total population assigned to District 9
is African-American. A similar pattern holds in the other three
counties Of District 12. lInieach of those counties, the
population on the District 12 side of the Congressional di
line 1s more strongly African-American while being more strongly
white on the other side of the line in an adjacent district.
When counties were split to achieve population equality, the
racial composition of the components differs little. When the
splits are for racial purposes, the differences are large.
I can infer from these data that race was a predominant factor in
the line drawing for Districts 1 and 12 and the adjacent
01:03. O00. 92 Inf ‘929914616: X 117 WI3348 BE JN
[LT —
districts in the 1997 North Carolina Congressional district plan.
vei. ee
21. I have also examined data related to city and town
splits in 199% North Carolina Congressional district plan.
Using a report titled Places Split by 97 North Carolina
congressional Districts prepared by Dan Frey, GIS Analyst, with
the North Carolina General Assembly Information Systems Division,
I created Tables 3 and 4.
13
¥1°d D1:01 00. 92 11 £9.991L616: Xe lI WI 345 90 !
TABLE 3
Proportion of Total Population in Split Municipalities and Census
Designated Places by Congressional District for 1997 Plan (HE 586--Plan A)
irvy/ Tow,
High Point
Winston-Salem
Greensboro
High Point
Lexington
Salisbury
Spencer
Thomasville
Charlotte
Cornelius
Davidson*
Mcoresville
Statesville
Troutman
Charlotte
Cornelius
Davidson*
Greensboro
High Point
Lexington
Mooresville
Salisbury
Spencer
Statesville
Thomasville
Troutman
Winston-Salem
5
n
n
aN
O
Y
O
Y
ON
Y
O
Y
OW
9
10
10
10
10
12
12
12
12
12
12
12
12
12
12
12
12
12
308
182,419
2,273
4,046
95,080
32,290
13,6%¢
8,818
17,837
3,211
5,243
9,006
74
54,270
[abridged]
73,981
32,833
2,522
4,442
6
6,249
186,112
304
0
0
3,997
1,024
73,535
1,752
3,407
42,236
15,677
8,143
6,687
10,522
2,488
1,2%0
5,246
74
12,272
Ow
O
B
O
O
y
Es
W
W
~J
Ww
*City or town is split across a county boundary.
Source: North Carolina General Assembly,
N
=
O
O
A
O
W
A
H
L
O
D
O
C
o
H
N
D
F
W
U
African-
17,
—
oO
(a
e)
oo
~~
~
Ww
38
)
~J
=
On
~ [e
e]
Ne
Y
N
a
~
N
E
Oy
BN
O
-
-
~
-
-
w
w
~
~
un
O
M
=
w
n
O
O
O
W
L
I
o
y
W
w
~
~
~J
Ww
41,99
W
w
a
w
o
o
D
O
J
0
0
O
N
M
S
o
y
W
w
Ul
Information Systems Division.
All information is based on that in the General Assembly’s
apportionment system.
14
Provided by Dan Frey, GIS Analyst.
117 WI1J34S 98 ON
TABLE 4
Proportion OI Total Population 1n Split Municipalities and Census
Designated places by City or Town for 13997 Plan (HB 586--Plan A) [abridged]
City/Town
Charlotte
Charlotte
Cornelius
Cornelius
Davidson*
Davidson”
Greensbor¢
Greensboro
High Point
High Point
High Point
Lexington
Lexington
Mooresville
Mooresville
Salisbury
Salisbury
Spencer
Spencer
Statesville
Statesville
Thomasville
Thomasville
Troutman
Troutman
Winston-Salem
Winston-Salem
co
9
32
9
12
Tota)
213,815
182,419
308
2+,213
0
4,046
88,441
25,080
6
37,200
32,290
2,885
13,696
0
8,818
3,211
12,324
58,243
74
1,418
89,215
54,270
White
196,172
312,935
304
1,752
0
3,407
78,981
42,236
6
32,833
15,677
2,322
S,142
0
&, 687
4,442
10,521
©
2,488
9,857
1,290
6,249
5,246
74
1,024
74,885
12,272
3
100.
72.
83.
22.
*City or town is ‘split across a county boundary.
Source: North Carolina General Assembly,
African-
Amer.
17,343
108,484
14,330
41,998
3
w
r
0
OO
o
p
Information Svstems Division.
All information is based on that in the General Assembly’s
apportionment system.
9 IMC
13
$9L99T2616: Xe
Provided by Dan Frey, GIS Analyst.
117 BIJ34S 98 ON
23. A similar pattern of splitting cities or towns is shown
for District 12. Nine of 13 cities or towns were split along
racial lines to create Congressional district 12. Five of the
Cities or towns split between district 12 and another district
involve placing a majority of the African-American population
into District 12 as displayed in Table 3. Also the four largest
cities assigned to District 12 are split along racial lines.
24. The above analysis is further confirmed by the listing
of split cities and towns in Table 4. iii tant, Takle 4.also
highlights the racial splits of the cities or towns assigned to
District 12. Again the difference in the figures for Charlotte,
Greensboro, High Point, Statesville, and Winston-Salem are large.
On the other hand, many of the cities and towns split between
other districts do not display large racial differences
(exceptions are Fayetteville and Raleigh).
pS RS
26. The discussion of not splitting precincts by
defendants’ experts misunderstands how racially homogeneous
precincts are today in North Carolina and other parts of the
nation. . .... i. louisiana'did not split a single precinct in the
creation of the two plans invalldated by the Hays court in the
16
21d 03:00 00, 92 170 $94991.616: <e4 117 WIJ34S 98 ON
Western District of Louisiana. Thus, given the homogeneous
racial character of precincts in North Carolina, it i$ guite
possible to draw districts in which race predominates using whole
precincts.
27. Next I present Table 5 which details at the precinct
level by county the assignment of precincts to Congressional
districts for the 22 counties that were split in creating the
1997 Plan (HB 586). For the counties which were split
predominantly on the basis of race I expect that the precincts
with the highest percentage of African-American persons will be
placed in either District 1 or 12 and the precincts with the
highest percentage of non-African-American persons will be placed
in an adjacent district. For the counties which were not split
predominantly on the basis of race, I expect to find a less
systematic assignment ¢f precincts to the two districts into
which the population is divided. To assist the reader in
following the tables, I have ranked the precincts from high to
low by the percentage of African-American population in each
precinct (see Table 5). The table also reports a breakdown of
the voting age population by race as well as the total population
by race. Finally, the district to which the precinct is assigned
in the 1397 Plan is noted in the final column of the table.
[Eran: insert Table 5 here]
II WHIE4S 95
39. . . . . The patterns revealed in Tables 1-4 are
reinforced by the precinct level data in Table 5 for the six
Split counties of District 12. Two groupings of counties are
most apparent: those where the difference between African-
American percentage of the total population assigned to District
12 is greater than 20 percentage points higher than the African-
American percentage assigned to the adjacent district and those
where the difference in the African-American percentage is less
than 20 percentage points. Forsyth, Guilford, Mecklenburg, and
Rowan counties fall into the former category, while Davidson, and
Iredell counties are in the latter category.
40. I first examine the precinct assignment pattern for
Forsyth County which includes the city of Winston-Salem and where
the most severe of racial disparities exist between Districts 5
and 12. All 15 African-American majority precincts in the county
are assigned to District 12, while all but four of the white
majority precincts in Forsyth County are assigned to District 5.
No precinct in which more than 20.39 percent of the total
population is African-American is allocated to District.5. - The
assignment of Forsyth County precincts between Districts 5 and 12
18
61d 01:01 00. 92 Nf £9.991616: xk 4 117 WHI134% 90 JN
1s the clearest pattern of the predominant use of race in the
creation of District 12 in the 1997 Plan in the Picdmont region
of: North Carolina.
41. I next look at the precinct assignment pattern for
Mecklenburg County which includes the city of Charlotte and where
very severe racial disparities exist between Districts 9 and 12.
All 28 African-American majority precincts in the countv are
assigned to District 12, while all the precincts where around 85
percent or more of the population is white in Mecklenburg County
are assigned to District 9. Some white majority precincts are
allocated to District 12, but for the most part these assignments
are made to provide contiguous paths from the African-American
majority precincts north to Iredell County so as to connect
African-American populations in Charlotte with those in Winston-
Salem, High Point, and Greensboro. The assignment of Mecklenburg
County precincts between Districts 9 and 12 shows a very clear
pattern of the predominant use of race in the creation of
District 12 in the 1997 Plan in the Piedmont region of North
Carolina.
42. I next examine the precinct assignment pattern for
Guilford County which includes the cities of Greensboro and High
Point and where severe racial disparities exist between Districts
6 and 12. All 17 African-American majority precincts in the
1°
0c °d 01:01 O00, SST 9.991.676: xB 117 WII348 St TN
county (all of which are in either Greensboro or High Point) are
assigned To District 12, while almost all of the precincts where
around 80 percent or more of the population is white in Guilford
County are assigned to District 6. Some white majority precincts
are allocated to District 12, but for the most part these
assignments are made to provide contiguous paths from the
African-American majority precincts in Greensboro and High Point
southwest to Davidson County so as to connect African-American
populations in Greensboro and High Point with those in Winston-
Salem and Charlotte. The assignment of Guilford County precincts
between Districts 6 and 12 is another clear pattern of the
predominant use of race in the creation of District 12 in the
1297 Plan in the Piedmont region of North Carolina.
43. I next examine the precinct assignment pattern for
Rowan County dncluding the city of Salisbury which is split
between Districts 6 and 12. Three of the four African-American
majority precincts in the county (the one African-American
majority precinct assigned to District 6 is a small non-
contiguous part of a large white majority precinct) are assigned
to District 12, while almost all of the precincts where around 80
percent or more of the population is white in Rowan County are
assigned to District 6. Some white majority precincts are
allocated to District 12 to provide contiguous paths from Iredell
County to Davidson County so as to connect African-American
20
18d 01:01. 00. 3%. 17C $9.991.616: <e4 117 BIZ34S 98 ON
population concentrations in Charlotte with those in Winston-
Salem, High Point, and Greensboro. The assignment of Rowan
County precincts between Districts 6 and 12 is another clear
pattern of the predominant use of race in the creation of
District 12 in the 1997 Plan in the Piedmont region of North
Carolina.
44. Turning next to the two counties split between
Congressional District 12 and an adjacent district where the
difference in the African-American percentage of the total
population is less than 20 percentage points, I examine first
Iredell County. Only nine precincts in this county are assigned
tC Congressional District 12, including two African-American
majority precincts in the city of Statesville. The white
majority precincts allocated to District 12 are there to provide
contiguous paths from Mecklenburg County to Rowan County so as to
connect African-American population concentrations in Charlotte
with those in Winston-Salem, High Point, and Greensboro. The
assignment of Iredell County precincts between Districts 10 and
12 provides further evidence of a pattern of the predominant use
Cf race in the creation of District 12 in the 1997 Plan in the
Piedmont region of North Carolina.
45. I next examine the assignment of precincts between
Congressional Districts 6 and 12 in Davidson County. A total of
21
A 11:01 = Cl
i Je RTI 9.991616: <k 1175001 34S id TI
20 precincts in this county are assigned to Congressional
District 12, including two African-American majority precincts in
the city of Lexington and cone in the city of Thomasville. The
white majority precincts allocated to District 12 are there to
provide contiguous paths from Rowan County to Forsyth and
Guilford counties so as to connect African-American population
concentrations in Charlotte with those in Winston-Salem, High
Point, and Greensboro. The assignment of Davidson County
precincts between Districts 6 and 12 provides further evidence of
a pattern of the predominant use of race in the creation of
District 12 in the 19397 Plan in the Piedmont region of North
Carolina.
47. veil xi "The state Of North Carolina subordinated the
splitting of county, city, and town boundaries to a desire to
allocate persons by race to a greater extent than necessary to
comply with the one-person, one-vote standard of population
equality. "This was particularly true in the drawing of Districts
l and 12 as well as adjacent districts. A total of 22 counties
and 41 cities and towns were split in the drawing of the 1997
North Carolina Congressional districting plan, for a total of 63
split political subdivisions. Only six counties and 15 citles
and towns were split to create the other districts (several of
22
117 WBI345 SON
the cities and towns were split because they are on a county
boundary and diffezent countics were assigned to different
districts). In the recent past no counties had been split to
create the 11 districts of the 1960s and 1970s, while just four
had been split to construct the 11 districts of the 1980s. The
maximum number Of counties needed to be split to fashion a 12
district plan is 11, allowing for one county to be split between
each two districts.
48. A report by David C. Huckabee, "Congressional
Districts: Objectively Evaluating Shapes," CRS Report for
congress (Washington: Congressional Research Service, The Library
of Congress), May 24, 1994, also contains information from other
states to compare with the experience of North Carclina in
Congressional districting.
49. Huckabee also provides information on the percentage of
split counties allocated to the Congressional districts of the
1990s. There are a large number of Congressicnal districts from
around the nation which have 100 percent of the counties split
which are allocated to a district. Most of these = plans
involving splits of large counties in the metropolitan areas of
the country and these plans are not comparable to the North
Carclina setting. No single district in the country is like
North Carolina 12 in splitting as many as six counties and sub-
23
ved 30:01 009 In $9.9912616: Xe 117 WIJ34S 98 ON
dividing 100 percent of them.
£ 50. Huckabee also provides information on the number of
places having populations of 10,000 or more and indicates how
many 0f these are split by district lines. In the 1997 plan,
District 12 has eight cities or towns 10,000 or more in
population, and all eight of them are split between districts.
Ne oe ide
53. A second way to assess the compactness of a
Congressional district is to use a variety of compactness
measures now standard in political science. These measures are
reported upon in two works~-1) Richard H. Pildes and Richard G.
Niemi, "Expressive Harms, 'Bizarre Districts,' and Voting Rights:
Evaluating Election-District Appearances after Shaw," Michigan
Law Review, Vol. 92 (December 1993), pp. 101-205, and 2) David C.
Huckabee, "Congressional Districts: Objectively Evaluating
Shapes," CRS Report for Congress (Washington: Congressional
Research Service, The Library of Congress), May 24, 1994. The
actual computations of the compactness scores reported in these
two works were conducted by Kimball Brace and Douglas Chapin of
Election Data Services, Inc., Washington, D.C.
54. Three measures of compactness are reported in the
Huckabee report for all 435 Congressional districts in the U.S.
adopted following the release of the 1990 Census of Population.
24
Sl d $1200. 200,92 {70 99914616: <& 4 117 WIJ34S 98 ON
Huckabee adopts two geographic measures--a dispersion measure and
a perimeter mcasure--—and one population measure.
55. . .... North Carolina's Congressional District 12 is
8till the least compact district in North Carolina on both
indicators of ‘geographic compactness . . . .. In Appendix Ei of
the Huckabee report, he reports a table containing the two
geographic compactness scores for the bottom ten percent of
Congressional districts in the nation. Using the criterion of
having at least one compactness score in the bottom ten percent,
North Carolina 12 would clearly continue in that compilation
I have also taken the perimeter and dispersion compactness
scores from the Huckabee report and revised the ranking order for
the worst districts on each measure . . . . North Carolina 12
ranks either 430 or 431 out of 435 in compactness using the
dispersion measure . . . . North Carolina 12 ranks either 432 or
433 of 435 in compactness using the perimeter measure. Thus,
North Carolina 12 continues to be the least compact district in
North Carolina and among the worst in the nation in terms of
geographical compactness.
56. Pildes and Niemi report geographic compactness scores
for the Congressional districts of the 1980s using the dispersion
and perimeter measures. These scores for the old 11 districts in
North Carolina are used to compare to the scores for the current
25
$d TROT 0, STI £999T2616: Xe 117 WIJ3dS 99 IN
12 districts in the 1997 plan.! The range on the dispersion
measure in North Caxoclina xuns from a low of .26 to a Righ.of i .57
and averages .36 across the 11 districts in the 1980s.
The range on the perimeter measure in North Carolina runs from a
low of .22 to a high of .46 and averages .30 across the 11
districts in the 1980s. . 0 This comparison reveals that
the 1397 12 district plan is less compact overall than the 11
district plan of the 1980s, using the two standard measures of
geographic compactness.
411. EVALUATION OF THE POLITICAL DEFENSE OF DISTRICT 12
* Uk
£4. 0.0 ymin, I have constructed a set of tables which
cross-tabulate the racial makeup of the population of each
precinct by county with the Democratic registration percentage,
the percentage of support for Democrat Harvey Gantt in the 1990
U.S. Senate contest, and the percentages of support for the
Democratic candidates for Lieutenant Governor and Court of
Appeals Judge in the 1988 general election. This cross-
tabulation will reveal that all African-American majority
population precincts are assigned to District 12 from the six
! Richard H. Pildes and Richard G. Niemi, "Expressive
Harms, 'Blzarre Districts,' and Voting Rights: Evaluating
Election-District Appearances after Shaw," Michigan Law Review, .
Vol. 92 (December 1993), Table 6, pp. 189-91.
26
TATE LE RL £9L99TLETE: XE L117 WI234S 98 IN
countles and that many of the precincts carried by Democratic
candidate= in the two contests of 1988 and the one contcsoct of
1990 were not necessarily assigned to District 12.
65. These results are displayed in Table 6 for each of the
ix counties and for Congressional District 12 as a whole. All
four Davidson County precincts more than 30 percent African-
American are in Congressional District 12. The weakest support
for a racial explanation comes from the 1930 Gantt table as four
of the five precincts in which he polled a majority were placed
in Congressional District 12. Charlotte’s former mayor ran
poorly in Davidson County, being held below 30% of the vote in 23
of the 41 precincts. Table 6 for Davidson County also
demonstrates that most of the precincts less than 30 percent
African-American in population but in which most voters are
registered Democrats were excluded from Congressional District
12. Analyses of the contests for lieutenant governor and Court
of Appeals show that no precinct in which the population was less
than 30 percent African-American but which cast more than 60
percent of their ballots for the Democratic candidate are in
congressional District 12.
117 LES Si ON
TABLE 6
DAVIDSON COUNTY
[omitted for printing)
FORSYTH COUNTY
Precincts included in Congressional District 12 when classified by measures of Democratic
strength and African-American Population
% Democratic Registration
% Black Population 50-599 60 - 69.9 > 70%
<30% 1/32 0/5 0
30-399 0/1 Va 0/1
40-499 0 0/1 2/2
50 -59.9 0 0 2/2
60 - 69.9 0 0 0
> 70% 0 0 13/13
% Support for Harvey Gantt, 1990
% Black Population 50-59.9 60-699 >70%
<30% 0/7 0 0/1
30-399 02 1/1 0/1
40-499 22 0 0/1
50-399 0 0 2/2
60-699 0 0 0 ;
28
&C d 21:01 OU, 98 17[ $9.991616: Xe 4 117 WIJ34S 98 ON
> 70% 0 0 13/13
% Support for Democratic Lt. Governor Candidate, 1988
% Black Population 50-599 60 - 69.9 > 70%
< 30% 0/8 0/1 0
30-399 0/2 1/1 0/1
40 - 49.9 0 2/3 0
50-599 0 2/2 0
60 - 69.9 0 0 0
> 70% 0 0 13/13
% Support for Democratic Court of Appeals Candidate, 1988
% Black Population 50 -59.9 60 - 69.9 > 70%
< 30% 0/6 0/1 0
30-39.9 0/2 Va 0
40 - 49.9 0 2/3 0
50-599 0 1/1 1/1
60 - 69.9 0 0 0
> 70% 0 0 13/13
GUILFORD COUNTY
[omitted for printing]
IREDELL COUNTY
[omitted for printing]
MECKLENBURG COUNTY
[omitted for printing] .
29
0g "d 21:07 00. 92 INC $9.991.616: Xe 4 LIT Wii3dS SN
ROWAN COUNTY
[omitted for printing]
SUMMARY FIGURES FOR ALL SIX COUNTIES IN CONGRESSIONAL DISTRICT 12
Precincts included in Congressional District 12 when classified by measures of Democratic
strength and African-American Population
% Black Population
<30%
30-39.9
40-499
50 - 59.9
60 - 69.9
> 70
% Black Population
<30%
30- 39.9
40 - 49.9
50-59.9
60 - 69.9
> 70
% Democratic Registration
50 - 59.9
30/139
2
60 - 69.9
18/45
8/9
3/6
> 70%
1/1
4/6
5/5
3/8
9/9
48/48
% Support for Harvey Gantt, 1990
50-599
13/56
6/8
4/4
1/1
0
0
30
60 - 69.9
312
5/5
0/1
> 70%
3/6
0/1
4/5
5/5
9/9
48/48
1 Xe 117. 010348 2 ON
% Support for Democratic Lt. Governor Candidate, 1988
% Black Population 50 - 59.9 60 - 69.9 > 70%
< 30% 18/45 2/12 0
30-399 7/9 4/5 0/1
40 - 49.9 2/3 4/5 2/2
50-599 3/3 6/6 1/1
60 - 69.9 0 1/1 8/8
> 70 0 1/1 47/47
% Support for Democratic Court of Appeals Candidate, 1988
% Black Population 50-59.9 60 - 69.9 > 70%
<30% 13/32 2/6 0
30-399 7/9 3/5 0
40 - 49.9 2/2 6/6 0
50 - 59.9 4/4 3/3 3/3
60 - 69.9 0 1/1 8/8
> 70 0 2/2 46/46
31
Jg¢'d 21:07. 00. $9.991L616: <&4 LIT Wli3aS 2 IN
66. . . . . Table €& for Forsyth County shows that all
precincte at least 50 pexcent African-American in total
population are included in Congressional District 12 for each of
the measures of Democratic strength considered. Once the
African-American population percentage drops below 50 percent,
then regardless of the Democratic strength registered in the
precinct, there is no guarantee that the precinct will be
assigned to Congressional District 12. As further evidence that
race 1s more important than party when sorting precincts between
Congressional District’s 5 and 12 in Forsyth County, if the
population is less than 40 percent African-American, then
regardless of how concentrated Democratic strength may be, it is
highly unlikely that the precinct will be included in
Cengressional District 12.
67. .". . . All 17 majority African-American Guilford County
precincts are in Congressional District 12. However a number of
precincts that are majority Democratic on the various measures
are outside Congressional District 12. The contrast is
pronounced in terms of party registration where three-fourths of
the precincts 50 - 59.99 percent Democratic by registration are
in Congressional District 6 rather than Congressional District
12. Even in the 60 - 69.99 percent registration range, most
precincts are excluded from Congressional District 12. Similarly
with the Gantt vote in 1580, 18 of 22 precincts in which Gantt
32
117 W1J33dS oad
got 50 ~- 69.99 percent of the vote are outside Congressional
Dimexict 12. Th= pattern repeats with the other Two sets of
election data. All of the heavily black population precincts are
in Congressional District 12 while only some of the heavily
Democratic precincts are included.
68. . ... . All three Iredell County precincts more than 30
percent African-American in population are in Congressional
District 12 while 15 of 21 precincts less than 30 percent
African-American are in Congressional District 10. The strongest
evidence of a racial explanation comes from the party
registration analysis where 13 of the 19 precincts less than 30
percent African-American black but majority Democratic in
registration are excluded from Congressional District 12. The
party explanation is best supported by the 1990 Gantt analysis in
which the only four precincts carried by the African-American
candidate are in Congressional District 12. Despite all but two
precincts having Democratic registration majorities, no more than
four precincts ever cast a majority of their votes for Democrats.
If I lower the threshold to 40 percent support for a Democrat,
results for the Gantt and the Court of Appeals contests would
support a racial explanation.
68. . . . . All 34 Mecklenburg County precincts more than 30
percent African-American are in Congressional District 12! In
33
72d cunt 00, snl 9991616: <k 117 W345 S90 JN
contrast, of the 99 precincts less than 30 percent African-
Amaexican, 82 are in Congreseional District 9. This alone
suggests that race played an very important role in selecting
precincts for Congressional Districts 9 and 12. The tables for
Democratic registration and support for Gantt in 1990 fit best
with an interpretation that race was more important than party
since in both of these presentations, the bulk of the 30 - 39.9%
black precincts in which Democratic strength is in the 50 - 59.9
percent range are excluded from Congressional District 12.
Focusing on the Gantt vote in 1990, the bulk of the 30 - 39.9
percent African-American precincts in which he polled 60 - 69.9
percent of the vote are outside Congressional District 12. The
1988 Court of Appeals vote provides the strongest support for a
party explanation for districting. IF, however, 1 include
precincts in which Democratic strength is 40 - 49.9 percent, then
most of the precincts are in (Congressional District 8, for all
four measures of partisanship.
70. . . . . Rowan County has only three majority African-
American population precincts (all more than 70 African-
American) and these are assigned to Congressional District 12.
The majority-white precincts in Congressicnal District 12 tend to
be the ones with the strongest support for Democrats. Every
precinct that gave Gantt in 1990 a majority is in Congressional
District 12 and all but one precinct that voted Democratic for
34
Std S10 00, 9 $9.991.616: ~& LIT WI 545 ed IN
lieutenant governor or court of appeals in 1988 is in
Congressional District 12. The strongest evidence for the racial
explanation comes from the registration data where most of the
precincts 50 - 89.9 percent Democratic in registration are not in
Congressional District 12. If I. drop the threshold down to 40
percent Democratic on each measure, then in the 40 - 49.9 percent
Democratic category, most precincts are excluded from
Congressional District 12 on each of the four measures.
Ti. * Finally, "2 rurn to the Table 8 portion. for all six
counties combined in Congressional District 12. District-wide
all African-American population majority precincts are assigned
to District 12. On the other hand, a large number of precincts
which demonstrated their willingness to support Democratic
candidates in the 1988 and 1990 general elections irrespective of
the race of the Democratic candidate are assigned to adjacent
districts and not Congressional District 12. For example, 60 of
the 98 white majority precincts won by Harvey Gantt in 1990 were
assigned to another district. If the motivation was to create a
Democratic majority Congressional District 12 which was
hospitable to an African-American Democratic candidate in the
1990 U.S. Senate contest, a large proportion of favorable turf is
not included in the district. A partisan district would have
attempted to include a majority ¢f those precincts and paid less
attention to race in the construction of the district.
35
Ld £1:01° QO. 2 inf 9991616: x6 117 WIJ34S 98 ON
Y. VOTER PARTICIPATION RATES WITHIN THE GEOGRAPHY QF
CONGRESSIONAL DISTRICTS 1 AND 12
76. In order to address the question of whether African-
American persons within the boundaries of Congressional Districts
1 and 12 of 1997 have less opportunity than white persons to
participate in the political process, I have estimated
participation rates for selected Democratic primary, Democratic
runoff, and general elections between 1990 and 1998 to determine
the patterns of participation among the two.
77. I present a summarization of these results in Table 7
for Democratic primary and runoff elections of the 1990s (see
Exhibits C and D for summaries of the regression and extreme case
analyses for the elections examined).
78. I present a summarization of these results in Table 8
for general elections of the 1990s.
20d gh Ser $9LYYTLETE: XB L117 WI34S 99 IN
TABLE 7
Participation Rates by Race in Selected North Carolina
Congressional Districts of the 1997 and 1998 Plans in Democratic
Primary and Runoff Elections of the 1990s
(Participation as % of Registration)
[abridged]
White
Office PArtic..
U.S. Senate
U.S. Senate
{P) a3
(
State Aud. (P
(
P
P
RY i. .097
) .098
Py .0B8S
) . 025
U.S. Senate
J.8. cong.
117 WIESE Sr ON
TABLE 8
Participation Rates by Race in Selected North Carolina
Congressicnal Districts of the 1997 and 1998 Plans in
General Elections of the 1990s
[=
(Participation as % of Registration)
(abridged]
White Afr. Am.
Year CD Office Partic. Partic.
1990 12 U.S. Senate . 807 . 572
1992 12 State Aud. «5533 .825
1996 12 U.S. Senate .9547 «473
1996 12 State Aud. “503 . 453
1998 12 U.S. Senate e411 .345
1998 12 P.5.4 Cong. .408 .34%6
38
bed 2107 00, 97 $9.991.2676: xe 117 WIJ3daS Sd IN
V. WHITE CROSS-OVER VOTING IN NORTH CAROLINA
79. I examine whether white voters in the northeast and
Piedmont regions of the state of North Carolina in particular
cross-over and give support to candidates of choice of African-
American voters in recent general elections. If white cross-over
voting 1s common in the parts of the state where Congressional
Districts 1 and 12 were created in the 1997 plan, this
information might have been taken into account by the architects
of the North Carolina congressional districting plan under
challenge. In order to address this question, I will first
report upon estimated white crossover rates using bivariate
ecological regression and extreme case (homogeneous precinct)
analysis for the selected statewide general election contests of
1990, 1992, 1996, and 1998 held within the boundaries of
challenged Congressional Districts 1 and 12 adopted in 1997.
Second, I will report upon estimated white cross-over rates for
the 1998 Congressional elections held within the boundaries of
the districts ordered by the courts in 1998.
80. In Table 9, I report my estimates of white cross-over
voting in the 1990 contest for U.S. Senate involving the
candidacy of African-American Harvey Gantt, in the 1990 contest
33
0rd S100 00 90 Tv $YLYYTLETE: XE 4 L171 BIJ3dS 98 IN
for State Auditor involving the candidacy of African-American
Bill Campbell, in the 1996 U.S. Senate and State Auditor contests
involving candidates Gantt and Campbell, and in the 1998 contest
for the U.S. Senate where John Edwards was the candidate of
choice of African-American voters. I conducted bivariate
ecological regression and extreme case analyses of these
elections. In both Congressional Districts of the 1997 plan,
African-American candidates obtained appreciable levels of white
cross-over support.
40
7d 21:01 C00, 97 £9.9912616: ~e 117 WIZ3dS Sg IN
TABLE 9
Estimated White Cross-Cwver Ratez in North Carolina
Congressional Districts of 1997 Plan A in Statewide General
Elections for 1990, 1592, 1996, ang 1998
(3 of Group Crossing-Over)
Candidate Weighted Regression Extreme Case
1990 i2 Gantt (B) 3737 32.6
1992 12 Campbell (B) 40.7 35.8
1996 12 Gantt (B) 35.3 82.1
199¢ 32 Campbell (B) 35.8 35.5
1998 2 Edwards 41.8 40.3
Note: The cross-over rate of white voters is estimated through
the use of weighted bivariate ecological regression and extreme
case (homogenous) analysis for each of the elections.
41
CV °d £1:01 0 00. 98 IM $9.991.610: <X€4 117 1334S 9b ON
dl. In Table 10, I report my estimates of white cross-over
voting in the 1998 Congressicnal elections contests in Districts
land J2,. v0. In both ‘Congressional Districts of the 139%
plan, African-American candidates obtained appreciable levels of
white cross-over support.
VII. ELECTORAL SAFENESS QF CONGRESSIONAL DISTRICTS 1 AND 12
82. To assess the electoral safety of Congressional
Districts 1 and 12 in the North Carolina Congressicnal
districting plan of 1997, I use electoral history included in the
1998 reports of plaintiffs’ expert Lee Mortimer and defendants’
expert David W. Peterson as well as reconstituted election
results for a number of recent statewide elections. In ny
scholarly work on state legislative elections, I consider any
election in which one candidate gets 60 percent or more of the
total vote among two candidates as being a non-competitive
election.
B83. . 7. I Find that within the boundaries of the district
that Peterson estimates that Democratic candidates won over 60
percent of the vote in two 1988 elections and the 1990 U.S.
Senate election between Jesse Helms and Harvey Gantt.
w* ok Kk
£1:0T 00, 9C INC 909912616: X 117 WIJ3dS 99 MN
TABLE 10
Estimated White Cross-Over Rates in North Carolina
Congressional Districts of 1998 Plan A in Congressional
General Elections for 1998
(¥* of Group Crossing-Over)
Candidate Weighted Regression Extreme Case
ear CD f Choice White % Whi 3
1998 1 Clayton (B) 30.4 33.3
1988 12 Watt (B) 32.6 31.0
Note: The cross-over rate of white voters is estimated through
the use of weighted bivariate ecological regression and extreme
case (homogenous) analysis for each of the elections.
43
Fv d 21:01 OC. es Ing $9.997L616: Xk 117 WiJi3aS 90 IN -
85. I have also reconstituted the precinct election returns
from nine racent statewide elections: the 1990 U.S. Senate
Democratic primary, runoff, and general elections; the 1992 State
Auditor Democratic primary and general elections; the 1996 U.S.
Senate and State Auditor general elections; and the 1998 U.S.
Senate Democratic primary and general elections. By allocating
the precincts within Districts 1 and 12 to both the 1997 and 1998
plans, I can determine how the various statewide candidates would
have performed within the two sets of districts. These results
are summarized in Exhibit E. Candidates of choice of African-
American voters are winning the Democratic primaries or runoffs
within both districts of both plans. And candidates of choice of
African-American voters are usually winning more than 60 percent
of the vote in the general elections within both districts under
both plans. These analyses suggest that neither the 1997 nor the
1998 plan is narrowly tailored.
CONCLUSION
86. On the basis of my above analysis, I conclude:
1) that race was the predominant factor used by the
state of North Carolina to draw the boundaries of the
1997 U.S. Congressional districts;
(2) that the state of North Carolina in creating the
1997 U.S. Congressional districting plan subordinated
44
SF °d 21:00 000, 9 INL £9.991L616: X64 117 WIJ34S 98 ON
traditional race-~-neutral districting principles, such
38 compactneasaz, contiguity, respect for political
subdivisions or communities defined by actual shared
interests, to racial considerations;
(3) that the political explanation for the Plan A
Congressional districts adopted in 1997 offered by
state defendants and their expert Professor Peterson is
flawed . ... ;
(9) that African-American voters residing in Districts
1 and 12 in the Act 586 plan of 1997 do not participate
at lower rates than white voters in recent state-wide
Democratic primary and runoff elections, indicating any
evidence that a history of official discrimination has
not led to politically significant differences in
political participation in Democratic primary elections
in the districts as drawn in 1997 (there are
participation differences between African-American and
white voters in general elections held within the two
districts of the 1997 plan, indicating that candidates
of choice of African-American voters will need some
white cross-over support to win within the two
districts;
(6) that more than sufficient levels of white crossover
voting exists in the northeast and Piedmont regions of
45
9v 'd 1:00 00. 9% ITC $9.9914616: Xe 4 117 WI1J3d4S ad IN
North Carolina such that fair U.S. Congressional
districts can be drawn that do not need to be majority
African-American in voting age population or voter
registration in order to allow African-American voters
a reasonable opportunity to elect candidates of choice
in U.S. Congressional elections; and
(7) that U.S. Congressional Districts 1 and 12 in the
1997 North Carolina plan are overly safe from the
standpoint of giving a candidate of choice of African-
American voters an opportunity to be elected, thus
questioning whether the plan was narrowly tailored to
gatisfy a compelling state interest.
I declare under the penalty of perjury that the foregoing
Declaration is true and correct.
Executed this tenth day of September, 1999.
/s/ Ronald E. Weber, Ph.D
46
Vd STO. 00. nl $9.991.676: XE 4 1171. W0II34E 0d Ji
TABLE 5
NORTH CAROLINA HB 586--PLAN A CONGRESSIONAL DISTRICTS OF 1997
Racial Composition of Total Population and Voting Age Population based on 1990 Census Data
of Precincts in Split Counties by Congressional District
[abridged]
COUNTY PRCTNAME TOTALPOP WHITEPOP WHTPPCT BLACKPOP BLKPPCT DISTRICT
Davidson Thomasville No, 2910 852
Ward No. 1 * 2731 BOS
Ward No. 5 * 2448 807
Thomasville No. = 2709 1830
Thomasville No. 3417 2506
Ward No. 4 * 2403 1906
Cotton * 4415 3807
Ward No. 2 * 3114 2612
Ward No. 6 * 2896 2502
Thomasville No. 3523 3149
Thomasville No. 3377 3034
W * = * *
Thomasville No. 9 4841 4784
Thomasville No. 3811 3753
Liberty * 3363 3345
Emmons * 2467 2450
Silver Valley * 2579 2562
Alleghany * 506 506
Denton * 1292 1292
Healing Springs 1644 1642
Jackson Hill * 790 789
Lexington No. 3 2950 940 ; 12
126677 113296 . ’ 96357
(8) NORTH CAROLINA HB 586--PLAN A CONGRESSIONAL DISTRICTS OF 1997
TABLE 5 (Ctd.)
Racial Composition of Total Population and Voting Age Population based on 1990 Census Data
of Precincts in Split Counties by Congressional District
PRCTNAME
abridged)
TOTALPOP WHITEPOP WHTPPCT BLACKPOP BLKPFPCT
Ju
l
LA
M. L. King Recreatio
14th Street Recreati
Mt. Sinai Church *
Ashley Middle School
Happy Hill Recreatio
Carver High School *
Kennedy Middle Schoo
East Winston Library
Lowrance Middle Scho
Memorial Coliseum *
Winston lake Family
Forest Pk. Elementar
Forest Hill Fire Sta
St. Andrews United M
Easton Elementary Sc
Brown /Douglas Recrea
Mineral Springs F. S
Hill Middle School *
Bishop McGuinness *
New Hope United Meth
Hanes Community Cent
Trinity Moravian Chu
Old Town Presbyteria
Middlefork #2 *
Brunson Elementary S
Broadbay #2 *
Middlefork ¥3 *
Latham Elementary Sc
Broadbay Kl *
South Fork Elem Scho
3134
2344
1711
2045
3386
4317
3165
2895
3102
2746
1662
2969
3022
4101
2606
5643
3743
2621
2775
4398
6044
2702
2860
3449
2303
4842
5497
2855
3128
3995
19
12
n
4
14
67
104
189
197
318
583
816
745
804
1610
1094
2896
2030
1457
1571
2758
4029
1787
1966
2426
1630
3671
4344
2249
2497
3254
C
O
N
W
N
(
S
L
I
N
G
I
&
oJ
=~
5
n
s
H
E
F
O
C
C
O
I
N
-
wn
oS
70
79
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. 68
. 98
41
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. 80
25
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62.
66.
66.
68.
. 34
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15.
71
66
14
74
18
82
.02
18.
18.
81.
77
83
45
3113
2328
1679
2002
3310
4209
2970
2686
2781
2133
2803
2200
2192
2451
1496
2658
1653
1134
1104
1584
1938
858
856
1004
641
1107
1121
566
618
682
o
e
J
eo
BY
a
a
2
~
.02
L
O
N
O
O
N
2
(-
Ju
l
Parkland High School 2761
* vr f 3
Lewisville #3 * 2694
Ardmore Baptist Chur 1673
Lewisville §2 * 4079
Abbotts Creek #2 * 4037
Bolton Swimming Cent 2889
Abbotts Creek #3 * 3690
Lewisville #1 * 5005
Clemmonsville #2 * 3404
Reynolds High School 2095
Kernersville #2 * 5693
Miller Park Recreati 2091
Abbotts Creek #1 * 4655
Trinity United Metho 2547
Clemmonsville #1 * 2359
Polo Park Recreation 1689
Jefferson Elementary 2434
Sherwood Forest Elem 972
Messiah Moravian Chu 1536
Summit School * 1775
Vihitaker Elementary 2021
Total 265878
Guilford [omitted for printing)
Iredell [omitted for printing]
Mecklenburg [omitted for printing)
Rowan [omitted for printing)
2479
2296
1643
235)
958
1506
1767
2010
196918
44
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h
24.
N
N
N
W
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