Complaint; General Assembly of North Carolina Bills 415, 313, and 87

    IN THE
FOR THE

RALPH GINGLES, SIPP
BELFIELD bnd JOSEPH
behalf of themselve
others similarly si

RUFUS EDII{ISTEN, iN
as the At,torney Ge
Carolina; JAMES C.
Governor of North
capacity as Presid
Carolina Senate;
in his capacity as
North Carolina Hou
tatives; THE STATE
ELECTIONS OF NORTH
R. KENNETH BABB, J
sR. r RUTH SEII{ASHKO,
BARNWELL and SHI
their official ca
members of the Sta
Elections of North
TIIAD EURE, in his
Secretary of the S
Carolina,

I. This act

of themselves and

regist,ered to vote

this action to enf

the election of th

election of the No

States Congress.

prevent any elect

t,ionment adopted

ment does not comP

because it dilutes

seek to prevent

Consitution which

North Carolina Ge

v.

Q-tc-*t

ITED STATES I STRICT COURT
DISTRICT: )F NORTH CAROLINA

RALEIGH DIV]T;ION

O BURTON, FRED
MOODYT on
and all
ted,

Plaintlffs,

is capacity
ral of North

EN, Lt.
rolina in his
t of the North
TON B. RMSEY

aker of the
of Represen-

OF
INA;

L. STICKLEY,
SYDNEY F. C.

HERRING, in
ities as
Board of

arolina; and
pacity as
te of Nort,h

Defendants.

from

North

crvrL oa*rooo

NO.

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CO!{PLAINT

I. Introduction

is brought, by four black citizens on behalf

ot,her black citizens who are eligible and

in the State of North Carolina. They bring

their right to have an effective vote in.
North Carolina General Assembly and in the

th Carolina Representatives to the United

ey seek declaratory and injunctive relief to

being conducted pursuant to the appor-

Carolina in 1981 because that apportion-

the one person one vote requirement andy with

the vote of black citizens. In addition they

orcement of the provisions of the North Carolina

rohibit dividing counties in apportioning the

ral Assembly because those provisions were not



Precleared in acco

1955r Ers amended, a

effect of diluting
In 1981, the

representative dist
years. These distr
the effect of dilut
the total deviation

District and the

over 22 percent; th
the largest House D

House District is
Thus plaintiff

reprexented in the

plaintiff Burton

the North Carolina

The 1981 appor

of the Constitution

dividing any county

North Carolina Hou

Senate. These prov

been submitted to

States District, Co

of the Voting Righ

provision is to pre

tive d-istri.t" and.

percentages or majo

and effect of the p

of plaintiffs and o

class.

Fina11y, in 19

a plan of districts
has the purpose and

and avoiding the

-2-

nce with 55 of the Voting Rights Act of

because the provisions have the intent and

e vote of black citizens.
th Carolina General Assembly created the

cts which will be used for the next ten

ts were drawn in order to dilute and with

the vote of black citizens. In addition,
tween t,h'e population of the largest Senate

lation of the smallest Senate District is
total deviation between the population of

trict and the population of the smallest

r 23 percent.

Gingles and other class members are under-

rth Carolina House of Representatives, and

other class members are underrepresented in

nate.

nt was enacted pursuant to provisions

f the State of NOrth Carolina which prohibit
n creating the legislative districts for the

of Representatives and the North Carollna

ionsr which were adopted in 1967, have never

Department of Justice or to the United

t for the District of Columbia pursuant to 55

Act of 1965r €ls amended., The effect of the

nt the creation of single member representa-

representative districts with substantial
ties of black registered,voters. The purpose

isions is to diminish the voting effectiveness

other black voters who are members of the

, the North Carolina General Assembly enacted

E the United States Congress. This plan

black citizens

voters.

ffect of diluting the vote of

ent,rat,ion of registered black



This action. is
1965r ds amended (h

51973 et seq, and

the Fourteenth and

Constitution, in or

tions for the North

Carolina Senate, a

apportionment, which

because of their ra

underrepresents th

2. The Court

and 1343 and 42 U.S

the statutes and Co

to enforce statutes

civil rights includ

. 3. Plaintiffs
1965r ds amended, a

to the United State

judge court pursuan

4. Plaintiffs

relief pursuant to

and 2202.

5. Plaintiff
adult black citizen
County, North CaEol

in elections of the

Senate.

5. Flalntitf
black citizen of th

County, North Carol

elections of the No

Senate.

7. Plaintiff
adult black citizen

rought pursuant to the Voting Rights Act of

eaf ter tr the Voting Right,s Act'r ) , 42 U. S . C .

r 42 U.S.C. SSI98I and 19831 pursuant to

fteenth Amendments to the United States

r to prevent defendants from holding elec-

arolina House of Representatives, the North

the United States Congress Pursuant to an

nies blapk citizens effective representation

and pursuant to an apportionment which

Jurisdiction
jurisdiction pursuant to 28

ng the right to vote.

claims under 55 of the Voting Rights Act of

under the Fourteenth and Fifteenth Amendments

Constitution must be determined by a three

to 28 U.S.C. S2284(a) and 42 U.S.C. S1973c.

seek declaratory and other appropriate

e Declaratory Judgment Act, 28 U.S.C. SS2201

III. Parties

. S1973c. This is an action

stitution of the United States

and constitutional provisions

u.s.c. ss1331

arising under

and an action

which protect

trGinglesr ) is an

resides in Gaston
;

iegistered to vote

Representatives and

1ph Gingles (hereafter

of the United States who

na. Gingles is properly

North 'Carolina House of

ipplo Burton (hereafter trButrtontr ) is an adult

United States who resides in Cumberland

nEl. Burton is properly registered to vote in

th Carolina House of Representatives and

red BeIfield (hereafter trBelfieldn) is an

of the United States who resides in Nash

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County, North Carol

in elections of the

North Carolina Sena

8. Plaintiff
black citizen of

North Carolina.

of the North Caroli

Senate, and the Uni

9. Defendant

State of North Caro

Attorney General of
State of North Caro

is his duty to rep

the State is intere

10. Defendant

Carolina. He is s

Governor of North

Senate.

11. Defendant

North Carolina. He

of the North Caroli

L2. Defendant

Carolina. He is s

State of North Caro

certify the results
States Congress and

and House of Reprei

13. Defendant

(hereafter nthe Boa

ing and conducting

North Caro1ina. It
primaries and gener

computing the resul

14. Defendant

Carolina and a memb

Chairman.

nE. Belfield is properly registered to vote

rth Carolina House of Representatives, the

, and the United States Congress.

oseph tloody (hereafter rMoody") is an

United St,at,es who resides in Halifax

y is properly registered to vote in
House of Representatives, the North

adult

County,

elections
Carolina

ed States Congress.

ufus Edmisten is an adult resident of the

ina. He is sued in his official capacity as

the State of North Carolina on behalf of the

ina. In his capacity as Attorney General, it
sent the State in all civil actions in which

ted.

James C. Green is an adult resident of North

d in his official capacity as Lieutenant

rolina and as President of the North Carolina

Liston B. Ramsey is an adult resident of

i; sued in his official capacity as Speaker

a House of Representatives.

ad Eure is an adult resldent of North

in his official capacity as Secretary of

ina. In that capacity it is his duty to
of aII North Carolina eleqtions to the United

:

all elections to the North Carolina Senate

ntatives from nulti-courrty: districts.
State Board of Elections of North Carolina

of Electionsn ) is responsible for supervis-

lmary and general electlons ln the State of

has the authority to control the conduct of

1 elect,ions. It ls also responsible for
s of multl-county elections.

R. Kenneth Babb is a resident of North

r of the Board of Elections and is its

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15. Defendant

F. C. Barnwell and

and members of the

16. As member

are authorized to e

Board of Electi.ons.

17. Plaintiff
class of all black

are eligible to and

- 18. The class

impracticabLe.

19. The quest

provisions of the

ment of the North C

Districts which are

common to the class

20. The clai
the claims of the o

2L. The repre

this controversy a

counsel to represen

protect the interes

22. The p

members of the c1a

varying adjudicati
dards of conduct

have only one plan

its legislat,ure and

cation of the 1egal

requirements of a f
patible standards

23. Since Nor

with only one appo

Carolina Constituti

-5-

ohn t.
hirley

Stickleyl SE,1 Ruth Semashko, Sydney

Herring are residents of North Carolina

Elections.

State Board of Elections, defendants

the powers and duties of the State

ard of

of the

erclse

IV. Class Action

bring this action as representatives of the

sidents of the State of North Carolina who

registered to vote.

is so numerous that joinder of all members is

on of the legality and constitutionality of

rth Carolina Constitution and the apportion-

rolina General Assembly and Congressional

at issue raise questions of 1aw and fact

of the representative parties are typical of

er class members.

entative parties have a personal stake in

have retained competent and experienced

them. They will fairly and adequately

of the class.

ution of separate actions by individual
would create a risk of inconsistent or

s which would establish incompatible stan-
defendants. The State of North Carolina can

apportion the representative districts of
congressional districts. Inconsistent adjudi-

ty of the current apportionment or of the

ture apportionment would establish incom-

conduct for defendants.

Carolina conducts elections in accordance

ionment, and in accordance with the North

, defendants have acted and refused to act



on grounds generall
appropriate final i
relief with respect

Senate and the Hou

25. In L967,

change the manner

26. Article I
c.gunty shall be div

27. The 1969

retained this provi

s3(3).
28. Prior to

Assembly to divide

that county was ent

North Carollna Cons

from dividing a cou

adopting Article II
divi.ded in the for

30. The 1969

retained this provi

s5(3).

31. Prior to
that most represen

districts.
32. Forty of

the Vot,ing Rights

33. Elections

by t,he 1967 amendme

34. The named

which are covered

amended.

applicable to the class, thereby making

junctive relief and corresponding declaratory

to the class as a whole.

NORTH CAROLINA CONSEITUTIONAL PROVISIONS
APPORTIONMENT OF THE NORTH CAROLINA GENERAL

Carolina General Assembly consists of the

V. COUNT ONE

ASSEMBLY.

24. The North

29. In 1967 ,

of Representatives.

rth Carolina amended

apportionment of the

, 54(3), was adopted

ed in the fornation

vision of the North

ion but renumbered it

its constitution to
General Assembly.

and provides that no

of a Senate district.
Carolina Constitution

to become Article II,

967 the North Carolina permitted the General

county in forming of a Senate district if
tled to two or more Senators; since 1967 the

itution has prohibited t,he General Assembly

ty in forming a Senate district.
he North Carolina Constitution was amended by

56(3) which provides that no county shall be

tion of a representative district.
evision of the North Carolina Constitution

ion but renumbered it to become Article II,

I

,i
967, the North Carolind Cdnstitution provided

i

t,ive districts were to be single member

rth Carolinars counties are subject to 55 of

tr 42 U.S.C. S1973c.

in each of these forty counties were affected

ts to the North Carolina Constitution.
plaintiffs reside in four of the counties

55 of the Voting Rights Act of 1965r ES

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35. North Ca

the North Carolina

United States for
North Carolina obt

States District
Constitutional Ame

have the effect of

account of race or

36. lhe purpo

North Carolina Con

2: above, is to di
to deny them the e

account of their r
37. In 1981,

its General Assemb

38. Accordi

population of Gas

Gingles resides, i
39. .If the

ing counties in cr.

could be divided i
40. Accordi

population of Cum

Burton resides, is
41. If the N

senatorial dislng

at least two sena

42. In each

the vote of black

vote of black citi
43. The 198I

the North Carolina

counties and, the

black citizens.
44. The Boa

tions for the Nor

lina did not submit the 1967

stitution to the Attorney

a1 pursuant to 42 U.S.C.

in a declaratory judgment from

t for the District of Columbia

ments do not have the purpose

nying or abridglng the right

amendments to

General of the

S1973c, nor did

the United

that the

and will not

to vote on

1or.

and effect of the L967 amendments to the

paragraphs 26 anditut,ionr ds described in
te the voting strength of black citizens and

ective utilization of the right to vote on

orth Carolina enacted a reapportionment of

to the United States census for 1980, the

County, North Carolina, in which plaintiff

162,558.

th Carolina Constitution did not forbid divid-
ting representative districts, Gaston County

three representative districts.
to the United States census for 1980r the

land County, North Carolina, in which plaint,iff
47 ,160.

th Carolina Constitution did not prohibit divid-
lcts, Cumberland County could be divided into
ia1 districts.
tance, dividing the county would concentrate

t,izens and enhance the effectiveness of the

DS.

pportionment of the General Assembly obeys

prohibition against dividing
effect of diluting the vote of

titutional
ore, has the

of Elections will
Carolina General

supervise

Assenbly in

and conduct elec-

even numbered

-7-



years from 1982-19

pursuant to Articl
Constitution unles

This practice viol
Carolina did not s

General of the Uni

Court for the Dis

with 42 u.s.c. L97

to 52 of the Vot

prohibit dividing

and senatorial dis

ing a substantial

ing a representati

of preventing bla

right to vote on

to deny and abrid

color.

U.S.C. 51983 to e

teenth Amendment

Constitution and

in accordance with an

Ir, SS3(3) and 5(3) of

the Court orders them

apportionment adopted

the North Carolina

not to do so.

A. First Clai for Relief
45. Plaintif I first claim for relief is brought pursuant

to 55 of Voting Rig

46. Defendan

conduct and supervi

Representatives and

Article II, SS3(3)

Constitution is to

it these provisions either to the Attorney

States or to the United States District

ct of Columbia for approval in accordance

B. Second CI for Relief

47. Plaintif I second claim for relief is brought pursuant

48. The prov

Rights Act of 1965 as amended, 42 U.S.C. 51973.

ions of the North Carolina Constitution which

unties in the establishnent of representative

icts rrere adopted with the purpose of Prevent-

r or majority of black voters from compris-

or senatorial district and with the purpose

citizens from effectively, exercising their
t of race or color. I

the North Carolina

citizens and, thus,

account of race or

49. The effe

C. Thlrd Cla for Rellef
50. Plaintif

ts Act of 1965r ES amended, 42 U.S.C. S1973c.

continue to enact apportionment plans and to

e elections for the North Carolina House of

the North Carolina Senate in accordance with

nd 5(3) of the North Carolina Constitution.

es 55 of the Voting Rights Act since North

of these provisions of

lIute the vote of black

thelr right to vote on

I third claim is brought

rce the equal protection

t,he Fifteenth Amendment

suant to 42 U.S.C. 51981.

pursuant to 42

clause of the Four-

to the United States



tative and senatori
preventing a substa

from comprising a r
the purpose of pre

ing their right to

Constit,ution is to

to deny and abridge

color.
IV. COUNT TWO

53. In 1981,

Ehe North Carolina

Laws of 1981 which

North Carolina Hou

to this Complaint.

55. A true a

Laws of 1981 which

the seats of the No

to this Complaint.

56. The f981

have Representative

number of citizens
57. The avera

Carolina House of

58. The plan

enacted has distric
Halifax County to a

member district
59. This

tion per member

percent.

51. The provi
which prohibit, divid

52. The eff

54. A true and

devi

res

ions of the North Carolina Constitution
ng counties in the establishment of represen-

districts were adopted with the purpose of

ial number or a majority of black voters

resentative or senatorial district and with

ting black citizens from effectively exercis-
te on account of race or color.

of these provisions of the North Carolina

lute the vote of black citizens and, thus,

eir right to vote on account of race and

MALAPPORTTONT,TENT OF THE NORTH CAROLINA
EMBLY

rth Carolina enacted a reapportionment of

neral Assembly.

accurate copy of Chapter 800 of the Session

tablishes representative districts for the

of Representatives is attached as Exhibit A

accurate copy of Chapter 821 of th Session

tablishes senatorial districts and apportions

h Carolina Senate is attached as Exhibit B

portionment, of the General Assenbly does not
1,

r Senate districts with a reasonably equal
'I

r Representative or Senator.

population per memberi for the North

esentatives is 48r954.

ich the North Carolina General Assembly

which range from a population of 551286 in
ulation of 43t724 per member ln the three

sed of Bladen, Columbus and Sampson Counties.

ion of population from the average popula-

ts in a overall range of deviation of 23.6

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60. Plaintiff
class members are u

Representatives .

61. The aver

Senate is 117,489.

62. Under the

Districts range f
Senat,e district
105,718 in the

63. This

54. Plaintiff
underrepresented in

65. At the t
General Asembly was

knew the extent of

average population

disregarding this
A. Fourth C1a

U.S.C. 51983 to enf

Fourteenth Amendmen

67. The appor

Representatives and

paragraphs 53 throug

66. Plaintiff I fourth claim is brought pursuant

Gingles, plaintiff Moody, and the other

the North Carolina House oferrepresented in

e population per member of the North Carolina

plan adopted by North Carolina, Senate

a population of L32,374 per senator in the

sed of Harnett, Lee and Wake Counties to
e district which consists of Guilford County.

at,ion of population from the average popula-

ults in a overall range of deviation of 22.'l

urton and the other class members are

the North Carolina Senate.

when the apportionment of the North Carolina

opted, the members of the General Assembly

e deviation of population sizes from the

r district, and they enacted the apportionment

iation.
for Re1ief

ce the equal protection clause of
to the United States Constitution.

Eo 42

the

nt of the North Carolina House of
e North Carolina Senate ,as described in

i'
65 above results in plaintiffs' being

underrepresented , s not comply with the "one person--one voter

lative apportionment, and denies plaintiffs
protection under the Fourteenth Amendment to

requirement for legi
their right to equa

the United States titution.
VII. COUNT TH : DILUTION OF BLACK VOTE IN NORTH

ERAL ASSEMBLY

The appor

enacted in

nt of the North Carolina General

apters 800 and 821 of the Session Laws of

and effect of diminishing the concent,ration

68.

Assembly

1981 has the purpose

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0

ss

and

A.

69.

of the

1973c.

70.

Carolina

to dilute
right to

are registered to
76. North Ca

preventing the bla

District from effe

of black voters and

black citizens.
decreasing the effectiveness of the vote of

Flfth Clai for Relief
Plaintiff
Voting Ri

I fifth claim is brought pursuant to 52 and

hts Act of 1965r EIS amended, 42 U.S.C. SS1973

The inten

General As

the vote

use their
B. Sixth Clai

71. Plaintiff
U.S.C. 51983 to enf

Fourteenth Amendmen

States Constitution

72, The inten

North Carolina Gene

1981 is to dilute
citizens the right

Carolina Session La

districts for the U

Complaint as Exhibi

A. Seventh CI

77. Plaintiff
to 52 and 55 of the oting Rights Act of

brought pursuant

amended, 42

VIII. COUNT : APPORTIONMENT OF UNITED STATES
CONGRES IONAIJ DISTRICTS

73. In 1981 th Carolina enacted a reapportionment of its
representative dist icts for the United States Congress.

74. A true a accurate copy of Chapter 894 of the North

of 198I, which establishes representative

and effect of the apportionment of the North

Iy which North Carolina adopted in 1981 is
f black citizens and to deny plaintiffs their
te effectively.
for Relief

I sixth claim is brought pursuant Eo 42

rce the equal protection clause of the

and the Fifteenth Amendment to the United

nd pursuant Eo 42 U.S.C. 51981.

and effect of the apportionment of the

1 Assembly which North Carolina adopted in
vote of black citizens and to deny black

use their vote effectively.

ited.states Congress, i= attached to this
c.

BeIf ield and ltoody are eligible to vote and

te in the Second Congressional District.
lina excluded Durham County from the Second

I seventh claim for

75. Plaintiff

Congresslonal Dlstr t for the purpose of and wlth the effect of
citizens of the Second Congressional

ively exercising their right to vote.

im for Relief
relief

1965,

1s

as

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0

teenth Amendment

tioned in accordan

Constitution.

defendants will su

the United States

represented by a 1

tionally constitu

Carolina Constituti

-L2-

U.s.C. S51973 and I 73c.

78. North Ca

districts for the U

effect of diluting
black citizens the

B. Eiqht Clai

79. Plaintiff
U.S.C. 51983 to enf

Constitution and pu

80. North Ca

districts for the U

effect of diluting
black citizens the

8I. In 1971 t

linars apportionment of its representative

ited States Congress has the purpose and

vote of black citizens and of denying

ight to use their vote effectively.
for Relief

I claim for relief is brought pursuant to 42

rce the equal protection clause of the Four-

the Fifteenth Amendment to the United States

suant Eo 42 U.S.C. S198I.

linars apportionment of its representative

ited States Congress has the purpose and

vote of black citizens and of denying

ight to use their vote effectively.
v. Equitable Relief

e North Carolina General

with the provisions of

Assembly was appor-

the North Carolina

82. In 1972,

ducted elections pu

83. Unless th

974, 1975, 1978 and 1980, defendants con-

suant to the L972 apportionment plan.

Court orders defendants otherwise, in 1982

rvise and conduct elections for the North

Carolina Senate, th North Carolina House of Representatives,

ress pursuant to Chapters 800, 82L and

of the North Caro1i a Session of 1981.

84. Plaintiff have no remedy at law which is an, adequate

prived of their right to vote and for being

islature that is iIIegalIy and unconstitu-

VI. Prayer for Relief

tlffs pray that the Court:

redress for being g

WHEREFORE plai

1. Convene a

provisions of 28 U.

ree judge court in accordance with the

2. Certify th

.C.52284i

s action to be a class act,ion;

3. Declare t t Art,icle II, 53(3) and 55(3) of the North

are in violation of 55 of the Voting Rights

and

894



,0

Act of 1965r ds ame

legislation and f
or certifying the r
ment which was enac

provisions until a

been submitted and

4. Declare Ar

of North Carolina

Act of 1955r :rs arne

ments of the United

from enacting any a

Assembly in accorda

participating in,
election for the No

House of Representa

accordance with. the

5. Declare

and North Carolina

800 and 821 of the

the equal protectio
United States Const

have representation

defendants from par

certifying the res

ment and from enact

representation dist
6. Declare

-Senate and the No

in Chapters 800 and

198I dilutes the vo

other class members

because of their r
Righrs Acr of 1965,

and Fifteenth Amend

in violation of 42

€d, and enjoin defendants from enacting any

conducting, supervising, participating in,
sults of any election pursuant to an apportion-

in accordance with these constitutional
unless these constitutional provisions have

oved ln accordance with 42 U.S.C. SI973c;

icle II, S3(3) and S5(3) of the Constitution

be in violation of 52 of the Voting Rights

edr and the Eourteenth and Fifteenth Amend-

States Constitution and enjoin defendants

rtionment of the North Carolina General

ce with these provisions and from conducting,

pervising or certifying the results of any

th Carolina Senate or the North Carolina

ives pursuant to any apportionment enacted in
e constitutional provisions;

t, apportionment of the North Carolina Senate

se of Representatives as enacted in Chapters

rth Carolina Session Laws of 1981 violates
clause of the Fourteenth Amendment to the

tution because the apportionment does not

district,s which are equal in size and enjoin
icipating in, supervising, conducting, or

ts of any election pursuant to this apportion-
ng any apportionment in the future which has

icts which are not "no!t in size;
at the apportionment of the North Carolina

Carolina House of Represent,atives as enacted

821 of the North Carolina Session Laws of

of black citizens and denies plaintiffs and

the right to use their vote effectively
in violation of 52 and 55 of the Voting

as amended, in violation of the Fourteenth

nts to the United States Constitutlon, and

.S.C. 51981 and enjoin defendants fron

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0

participating in,
results of any e1e

enacting any appor

effect of diluting
race i

7. Declare th

districts for the U

894 of the Session

members who reside

right to use their
Vgting Rights Act o
Fourteenth and Fift
Constitution, and i
defendants from par

certifying the resu

tionment and from

States Congressiona

or effect of dilut
race i

. Award the

attorneysr fees, to

9. Grant plai
be just and appropr

rhis /6 a^v ot &{k ^'0*e+ , 1e81.

HAI,IBERS
ESr Ferguson, Watt, Wallas,

Adkins & Fuller, p.A.
951 South fndependence Boulevard
Charlotte, North Carolina 28202
704/37s-8461

JACK GREENBERG
JAMES tt. NABRIT, IIr
NAPOLEON B. WILLIAMS, JR.
10 Columbus Circle
New York, New York 10019
212/s86-83s7

Attorneys for Plaintiffs

-14-

Purpose or

of their

.l

pervising, conducting or certifying the

ion pursuant to this apportionment and from

onment in the future which has the

he vote of black citizens because

t the apportionment of the representative
ited States Congress as enacted in Chapter

yrs of 198I denies plaintiffs and other class
n the Second Congressional District their
te effectively in violation of 52 and 55 of
1965r dS amended, in violat,ion of the

nth Amendments to the United States

violation of 42 U.S.C. 1981, and enjoin
icipating in, supervising, conducting, or

ts of any election pursuant to this appor-

cting a plan of apportionment of United

Districts in the future which has the purpose

the vote of black citizens because of their

ts of this action, including reasonable

plaintiffs; and

tiffs such other and further relief as may

ate.



0
GENERAL ASSEMBLY OF NORTH, CAR.0LINA

RATIFIED BILL

CEIPTEB 8OO

EOtrsE Br11 415

AN ACl IO TPPOETIOX THE DISIBICTS OF TEE T{ORTE CIBOTINA HOUSE:08

R EPBESETITATI VES.

The General assenbly of xorth caroliaa enacts:
..''... Section 1. G.S..120-2 is revrittea to reah:

fie(l. --Por the purpo5e of
nolinatiag aatl electing nenbers of tLe f,orth Caroliaa Eouse of
Representatives iu 1982 aucl every tro years thereafter, tbe State
of North carolioa shall be divltled iuto forty-four clistricts .as

follors: .

District 1 shall cousist of caadleu, chouan, currituck, DaEe,

Pasguotank, PerquiDaDs, ryrrell, ancl rashiugton. couaties, an6

sha1l elect tyo Eepreseltatives.
District Z shall consist of Beaufort

shall elect one gepreseDtative.

Distrj-ct 3 sharl consist of cravea, Jones, leuoir, aad panlico
counties, aucr sharr elect three Represeatatiyes.

District q shall coasist of carteret aacl onslor counties, aacl

sball elect tbree gepreseatatives.

Gates, .Eertforil, Hartia,
and ilorthaupton couoties, andl shall elect tro Repieseutatiyes.

District 5 shall coasist of Ealifar couutyrlaad shall elect one

ancl Eycle Counties, and

EXTIBIT A--5 pages



t r1 i

District 7 shall '- coasist of E<lgeconbe, ' Nas- , and tlj'lson

counties, and shaltr elect four'Bepresentatives.

District I slaIl consist of dreene aud Pitt Counti.esi and sball \-/

District g shalL consist of nayne County, ancl shall elect-tro

BepEeseDtatives ' ' ''": '::'"-- 
,

District 1O shall consist" of '. Bobeson County r,' and shall elect

tro RePfeseDtatives. ::':' : :a'a'-":: ':'i ' ' 'iri':- : ..r;l

District 11 shall cousist of tsruusrick, priplin, ancl Pencler

Countibs, and sball elect tro BePresentatives. :1 -

District 12 sball coasist of . Ner.'.Eanover County, .and shall

elect tro Represeutatives.

District 13 sball cousist-of, CasYellr'Grauville, Person, VaBce,

anti larreu Countiesr. aDcI shall elect three *Bepreseutatives. !..1

a

District 14 shall cousist of 'FrankU.n'ancl JohnstoD Countiest

arrrl -shal]. elect tro ReDresentatiVes. ,,' i -, '-J

District 15 shall consist of Eake County, anil'shall elect,'six

RePreseDtatives .l - :.i ' -" :'i ' 'i :i"' :' ' , .'

Distiict. 1e shall consist of Durb,au couDty, aucl shall elect

thEee Eepreseatatives.

District 17 shall cousist of Chathan antl orange counties, aud

shall elect tuo Represeatativ€s.

District 18 shall consist of Harnett autl Lee Couuties, andl

shall eJ.ect tuo RePresentatives. . 
.

Distrj,ct 19 shall coDsist' of Elaclen, Colunbus, antl Sanpsou

Counties, anil sball -elect three Bepresentatires.

I

I

,t
j

,;
;\J

Eouse Bill 4152



ra
,

c.

tristrict 20 shall consist of Cunberland County, aud shall elect

five Representatives. : 'j ':

= 
District 21 sball consist of Eoke.aad Scotlancl Couuties, aDd

shall eLect oDe Representative. .. :

:

. District 22 shall'consist of Alanance ancl 'Bockinghau Counties, 
i

District 23 shaLL cossist of Guilforcl Couaty, aucl sball elect

District 24 shall consist of Randolph County, and sbal.l elect,

tro Representatives. -' ,

District 25 shall consist of Uoore'County, and shalJ. elect oDe.

Represent ative. . -..:. i':

Distri'ct26sha11cousistofAnsouaucllloutgoneryCounties,.antl..

:

District 27 sball coosist of RicL,uond County,'aacl. sball elect

oDe Represeutative '

District 28 shall consist of Alleghaay, Ashe, Stokes, Surry,

and liatauga counties, aact shall elect three Representatives.i :.-

District 29 shall consist of Sorsytl Couatyr'aotl shaIl elect

District 30 sball consist of Davitlson and Davie Couaties, ancl

shaLl elect tir,ree Represeltatires..

District 31 shall consist of Roran Couuty, aad shall elect tro

:onsist of Stauly County, aud shall elect oneDistr.
'!

I: Represetrtative.
i

I

v.i

House Bil.l 415



c, 
n i r '

_ Dis:trict 33 sha].l do-sist of Cabarrus-aud, Union -ounties, aDtl

shall elect three BepreseDtatives. ' ' ' ;

,i

Drstrict 34 shall coosist of' Ca1duellr Iilkes, ancl Yadkin \J
Counties,aucisha].Ie1ectthreeBepreseutatives.

llistrict 35 shall consist of A.leraacler ancl lredell Counties,

and sha1l elect tuo RepEeseatatiyes.

Drstrict 36 sbalJ. coosist 'of. "lleckleuburg County, aud shall
elect nine Bepreseutatives.

.

District 37 shal.l consist of Catarba:Couuty, aucl shalJ. elect

tuo Bepreseatatives. :' ,' ' ,

' District 38 sha1l consist of 'Gaston aod, Liucola Counties, ancl

shall elect rour Represeutat,ives. ' i.

District 39 'sball consist of Avery, Burke, and [itchell

Counties,audshaI1e1ecttIoBePreseatatives..

District 40 shall cousist of Clevelaucl, Polkr. and Rutberfotd, -

Counties, and. shall elect tbree Bepresentatives. :: j

District 41 shall consist of UcDouel].'and Yancey CouDties, and

shaI.L elect one BepreseDtatiYe.

District 42 shal1 consist of Buuconbe, Heaclersou, aud

fransylvaaia Counties, and sUatt elect five Representatives.

District 43 shalJ. cousist of Eayuood, Jackson, Uadison, anil

Srain Couaties, aotl shalJ. elect tro Bepiesentatiyes.

District 44 shal.J. cousist of Cherokee, Clay, Grahan, aod lfacon

Counties, aod shall elect one.:Bepreseatative. tt

il
:

i

House BiIl 415



o.

this the

Sec. 2.

In the

3rci ctay

q

:

this ,act

Geneial

of July,

, it
I.:
i

is ef,fective' uPoD' ratificatio[-

Asseubly read three tiues anil:ratified,

1981.

JAMES C. GREEN

Janes C. Greeu

Presicteqt of the Senate

LISTOT{ B. RAMSEY

Listou B.

Speaker of
,'

Eansey

tLe House of Bepresentatives

House Bill ll15



GENERAL ASSEMBLY OF NORTH CAROLINA

SESSION 1981

RATIFIED BILL

cEtPrEE 821

. . SENAIE. BILf, 313

ATI ACT TO ESTABLISB SEXATOEITL DISTEICTS Af,D TO APPOEIIOX SEATS

fhe General Assenbly of Xorth Carolina euacts:

Section 1. c. S. 120- 1 is hereby tteletecl aatl the

folloring iasertecl iu lieu thereof:
tt I 120- 1- Seratots. --For the purpose of nouinating aacl

-electiog lenbers of the senate in 1982 and. eyeEr tro years

thereafter, senatorial districts aEe establishetl and seats in the

senate are apportionetl anoBg those dlistricts as follors: . :.

District 1 shall coosist of Beaufort, Bertie, candlen, chorau,

Currituck, Dare, Gates, Eertford, Eycle, llorthanptoa, pasquotauk,

Perquiaans, Tyrrell, aud lasbington Counties aDa shall elect tro
Seaators

District 2 shall coasj.st of Carteret,
Couuti.es aucl shall elect oae Seaator.

District 3 shall cousist of Oaslou Couuty

Senator

District lt shall cousist of Ier Eanover and

shall elect one SeDator.

District 5 sball consist of Duplin, ilones,
;ancl shall elect oae SenatoE.

District 6 shall- consist of Edlgecoube aadl

shall elect oue Senator.

Craven, aud Paalico

antl shalI elect one

Pentler Cousties and

i

aDd Lenoir Couaties

E

HGIIBIT B--4 pages

al.ifar Counties aafl



t:'i]'t

'"District 7 shall eons-st of Eartia and Pitt Counr-res aad sb,alI

' i. :

District 8 sharl consist o.f, Frariclir, tash, vance, rarre!, ancl

lli.Lson Couaties and shall e]'ect.$ro ,Seuators.

District 9 shall coasist of GEEeEe aad nayDe Corr^aties aDd shall
elect one Senator. . ,,= 

' 
i,: i

District 10 shal-l coosist of, Joh,astoa aurl Saopson Couaties aacl

shall elect oue Senator.

District 11 shall coasist of'Cnuberlaucl County anil shall elect
tro S€sators.

District 12 shall consist'of' Blatleo, Bruusrick, ancl coluubus

Courrties aacl shall elect one SenatoE.

. District 13 shall . consist of Eoke and Bobesou Couuties..and
'\ l{i

shall elect oDe SeDator.

District lrl shall consist of. .Durhau, Grauville, ancl person

Counties aarl shall elect tro SenatoEs.

!

DistEict 15 shall consist.of Earaett, Lee:aud Hake Counties aDg

shall elect three Seaators. , ; .

.t

. District 16 shall coasist'of ;AiLleghany, Ashe, Surry aad tlatauga

Counties ancl shall elect one Setrat,oE.

Dlstrict 1? shall coasist'rof Eock5.aghar aadt Stokes Couaties aacl
I

sball elect one Senator.

. Di.strict 18 shall . coasj.st of Chathan., loore,
Raatlolpb Counties aucl shall elect tro Senators.

Oraage, .aocl

.

I

,

..
DistEict 19 sh.all consist of lasotr: UoatgoB€r:i, gicbload,

scotraact, Stanly, aatl tlrion couaties and I suair elect tro

ll
ri
!l,:ri
ll| ;.

Sed,ate Bill 313

SeDators.



I

District 20 sha1l coulist of alauance autl casrell couuties ancl

shaII elect one Seoator.

District 21 shall coosist of Forsyth county aud shall elect tro
Senators

District 22 shaIl consist of Guilforcl couoty antl shal1 blect
three Senators 

:

Dis trict 23 sh al]. consist of Daviclson, Davie, ancl Roraa
Counties aucl sball elect tro Seuators.

District 24 sharr consj.st of cabarrus and ueckLenburg couDties
anil shall elect four Sena-toEs.

District 25 shall consist of lLe:auder, catarba, rrederl, aurl
radkin couaties a,,d shall erect tro seaators.

District 26 sharl coasist of avery, Burke, calttrelr, 6itchelr,
antl Hilkes counties aacr sharr elect tro seuators.

Rutherforcl counties aud sharl elect three seDators.
District za sha1l cousist of Buuconbe, f,aclisou, gcDorerl, aad

Yancer counties ancl shalr elect tro seDators.
District 29 sharl consist of cherokee, cray, Grahan, Eayroocr,

Headerson, Jacksoa, [acoD, polk, suaiu, ancl rransylvaaia counties
and sball elect tuo SeDators.rr

3

District 27 sball cousist of Cleve

SeDate BiIl 313



. t ii'
2'.' rUfS cct. i.g effective uPo[ ratifr;atioa. '' ; j'Sec- 2. Tht-S'c€t

tiues ancl ratified,
',;, .;.1. :.'i " i:.,. r':'.1. ,j

. LISIOilI B. RAMSEY ] r

ListDo 8..Bansey

Spei},er: of tLe Eouse of' Bepreseatatives

a

I.

t

I

I

I

tt.i

,

;l

,:
,J

enate BiIl 313

//



.t

GENERAL ASSEMBLY OF NORTH CAROLINA

SESSION 1981

RATIFIED BILL

cBlPtEE 894

AII ACT TO DTVID E NORTE CTBOIIIX A IXTO ELEVEII CO}IGBESSIOIIL

Tbe Geueral. lssenbly of llorth Caroliua eoacts: '':- 
.1,

Section1.G.5.163-2o1isrerritteatoreadl::
ns 163-201. !ouqressioual districts seeiitiea.--(a) For the

PurP.ose of noriuating audl ele'ctiug nelbers of the Eouse . of
Bepresentatives of the CoDgress of the Uaitect Stites is 1982 aucl

every tuo years thereafter, the'State of f,orth Caroliaa shal1 be

divicted ilt,o 11 rlistricts as f ellersr
FIIiST DISTRICT: BeaufoEtr. Bdrtie, Canden, Carteret, Ch6ran.

aveD, Currituck, Dare, Gatesr:Greene, Eertford, Eydle, Leooir,
Eartio, NorthanptoD, Panrico, pasguotank, perquinans, pitt,

an.;l Er-at^i --r .Tyrrell, and lashington Couaties. t

SECOtiD DISTRICT: Alanasce, Casrell, 'Chathan, Eclgecoube,

Franklin, Grauville, Ealifax, Xash, peEsoD, vaaqe,' Iarre!r. ald

llilson Counties.

THrRD DrsrRrcr: 8lailea, DupJ.ia, EarDett, Jol.uston, iloaes, Lee,
' ODsIor, Peucler, Sanpson, aacl Iayle Couuties.

. fOUBTts DISTBICT: Durhan', Orange, aad fake Couaties

fIFIH DISTRfCT: llelantler, Allegbauy, Ashe, Forsyth,

Bockingban, Stokes, Surry., aud litrkes Couaties.

sIxtE DISTBICf : .DSviilson, Guilford, and aaadolph Couaties; aDd

ouly tbe folloring tornships of loore Couaty: Tovnsbip 1

E)GIIBIT C--3 pages

1-_



&1*.arrage) , T,orD.ship J (sbeffieiLcrs) , Tovnship 4 (Bitters) ,
Tornship, 5 (Deep Biver) , aad roraship. G (Greearoocr) ..':'.'

sEVEil'.r'H DISIRICt:. Bruus*ick, Coluobus, Cuoberlaud, Ifer
HaloveE, aud Bobeson Couaties.-. :.:i ,,_

' ETGHTH DrsrRrcr:. AEso[r. ca:bar.ruge Davie, goker. uoatgooery,
Richoord, RoraD, scot.landr, staulyra. uaiooa ancl. yadki-n couutj.es;
and alr tornships of f,oore couutl ercept:, louaship 1 (carthage),
lornsirip 3 (sbeffields) ,, rornship 4 (Bitterst , tornship 5t (Deep

hiver), Tounship 6 (Greearood).

NrNlH, DrstRrcr: rredell, Linc"olo, .aod Eeckrenburg couDties.

.":::l; "".'-::::;" ;":;::"*u*"*"e'ca1<1re11' 
cata''"' clevelandr'

ELEvEUTH DrstRrcr.: . Buncouber, c\erokee, clay, Grahan, Hayroodr,

Hendersou, Jackson, uacoDr, EadisgDr,. f,cDorellr, uitchelI, polkr.
Rutherf orcl, srain, Traasyrvaaia, BD-d,. raacey couaties. 

.(b) the Dane aocl bouuilaries of: toraships specified in rhie
section. aEe as they reEe. legall.y dlefiaerl aud in effect . as of
Janua.y lr.1980, and recognized. ii. the. 19go t.s.. census.rt

..

Seuate BiLl A7



,-)"
,.o

t

l
:

sec- 2- This act. is effective upou ratification.
rn tbe Geoeral assenbry read three tires aurl ratified,

tbis the 9th tlay of iluly, 1991.

JAMES C. GREEN

Presiileut of tbe Senate

LISTOT{ B. RAMSEY

Listoa B. Barsey

Speater of the Eouse of BepreseDtatives

0

I

Senate Bill O7