Fax to Cox from Carraway RE: Edited Joint Appendix
Correspondence
July 26, 2000

50 pages
Cite this item
-
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 July 30, 2025.
Copied!
State of North Carolina Department of Justice : P. O. Box 629 MICHAEL F. EASLEY RALEIGH ATTORNEY GENERAL 27602-0629 FAX TRANSMISSION 10... etl Cow NZ / FAX NUMBER: | NO. OF PAGES: __ 5) FROM: _ "yr au SARE TELEPHONE NUMBER: (919) 716-6900 FAX NUMBER: (919) 716-6763 SUBJECT: Luosaskee a (pen Li COMMENTS: i wan Chis. Ri = an Ch ifmedl tee. A 2, CONFIDENTIALITY NOTE THE INFORMATION CONTAINED IN THIS FACSIMILE MESSAGE IS LEGALLY PRIVILEGED AND CONFIDENTIAL INFORMATION INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE READER OF THIS MESSAGE IS NOT THE INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY DISSEMINATION, DISTRIBUTION OR COPY OF THIS TELECOPY IS STRICTLY PROHIBITED. JF YOU HAVE RECEIVED THIS TELECOPY IN ERROR, PLEASE IMMEDIATELY NOTIFY US BY TELEPHONE AND RETURN THE ORIGINAL MESSAGE TO US AT THE ADDRESS ABOVE VIA THE UNITED STATES POSTAL SERVICE. THANK YOU. \WPSINSPLIT\FORM\FAX.SHT &3 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 60d 00:07 00a IT[ $9.99T.6T16: Xe 4 JIT WHIT3HS Sid ON 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 BY 51 a . 68 . 98 41 «37 . 80 25 +23 .28 «10 . 60 26 «38 “32 «23 .59 «61 62. 66. 66. 68. . 34 a0, 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 a . [e h 24. N N N W W W W W D D O Pe st LP S [A SI 4 B e ) E E N | a a a @ N- S ~~ QD A D I N MN W o y No C Q O W N N Y W a C N G o o w aN 0 r o on NM .10 83 ] A L O n e n L O L A e o O, m