Plaintiffs’ Response to Defendants’ and Defendant-Intervenors’ First Request for Production of Documents

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UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF NORTH CAROLINA 

WESTERN DIVISION 

Civil Action No. 4-96-CV-104-BO(3) 

MARTIN CROMARTIE, et al., 

Plaintiffs, 

V. 

JAMES B. HUNT, JR. in his official 

capacity as Governor of the State of North 

Carolina, et al , 

PLAINTIFFS’ RESPONSE TO 
DEFENDANTS’ AND DEFENDANT- 

INTERVENORS’ FIRST REQUEST FOR 
Defendants, PRODUCTION OF DOCUMENTS 

and 

ALFRED SMALLWOOD, et al, 

Defendant-Intervenors. 

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PLAINTIFFS, MARTIN CROMARTIE, THOMAS CHANDLER MUSE, LOIS WEAVER, JOEL 

K. BOURNE, R.O. EVERETT, J.H FROELICH, JAMES RONALD LINVILLE respond to 

Defendants’ and Defendant-Intervenors’ First Request for Production of Documents through their 

counsel as follows: 

1. Produce copies of all prepared testimony, photo-offset conference proceedings, 

affidavits and reports prepared by your experts in connection with other voting rights proceedings.  



  

” w 

RESPONSE: Plaintiffs object that this request is overly broad and burdensome, as Dr. Weber 

has testified in over 40 such proceedings. However, in response to this request, we are providing his 

expert reports from the Shaw cases he participated in. 

2. Produce copies of deposition or trial testimony by your experts given in connection 

with other voting rights proceedings. 

RESPONSE: Plaintiffs object that this request is overly broad and burdensome, as Dr. Weber 

has testified in many such proceedings. However, in response to this request, we are providing all 

his depositions and all trial testimony he has been able to locate from the Shaw cases he participated 

in. 

S. Produce each document identified or relied on in response to Defendants’ And 

Defendant-Intervenors’ First Set of Interrogatories (including all maps). As to any map required to 

be produced, please produce all supporting data and documentation or related writings, including 

electronic communications. 

RESPONSE: The documents identified or relied on in response to Defendants’ And 

Defendant-Intervenors’ First Set of Interrogatories are found in the VRA Section 5 Submission to 

the Justice Department or other documents already in your possession. 

 



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4, Produce any and all alternative congressional districting maps of which you are aware 

and which you believe would have met constitutional and Voting Rights Acts requirements if they 

had been adopted by the General Assembly in 1997. Please produce such maps, including all 

supporting data and documentation or related writings, regardless of whether they were in existence 

in 1997 or whether the General Assembly had them before it. 

RESPONSE: In response to this request for production, plaintiffs offer the following list of 

plans which consist of all the plans we are aware of which meet or approach the constitutional 

requirements of Shaw v. Reno and related cases. Several of them may not fully satisfy the 

equipopulous requirement. These plans are all found in the VRA Section 5 Submission to the U.S. 

Department of Justice for the 1997 Congressional Plan: 

. 1996 Whole County Adjusted 

. 1996 Whole County Cong Plan 2 

. 1996 Whole County Cong Plan 3 

. Charlotte Observer 1996 Plan 

. Cong. District Executive Plan 

. Lee Plan-Congressional 

In addition, plaintiffs incorporate by reference the materials produced in response to Request 

#8, and the statements of Interrogatory answer #1.  



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5, Produce any and all alternative maps of one or more congressional districts, but fewer 

  

than all districts, of which you are aware and which you believe would have met constitutional and 

Voting Rights Acts requirements if they had been adopted by the General Assembly in 1997. Please 

produce such maps regardless of whether they were in existence in 1997 or whether the General 

Assembly had them before it. 

RESPONSE: We are not aware of any such maps which meet constitutional and Voting 

Rights Acts requirements, either published in the 1997 and 1998 VRA Submissions, or found 

anywhere else. 

6. Produce any writings or electronic communications that reflect the terms, conduct, 

and results of any contests involving the drawing of maps for one or more congressional districts. 

RESPONSE: Plaintiffs’ response to this request for production is attached. 

7. Produce copies of any and all congressional districting maps, including all supporting 

data and documentation or related writings, whether for one or more districts or all twelve, that were 

created, produced, or provided in connection with any contests involving the drawing of maps for one 

or more congressional districts. 

 



  

® » 

RESPONSE: The copies of the maps and supporting data and documentation from the 

ADCR contest were turned over to the General Assembly in 1997. Several of the districts drawn in 

the  ADCR contest can be found in the 1997 VRA Section 5 Submission to the U.S. Justice 

Department. 

8. Produce any maps, including all supporting data and documentation or related 

writings, that were created or provided to plaintiffs and their counsel by any civic organizations, such 

as the League of Women Voters. 

RESPONSE: Plaintiffs’ response to this request for production is attached. 

This the 4th day of October, 1999 

Ted NE 
  

Robinson O. Everett 

Everett & Everett 

N.C. State Bar No.: 1385 

Attorney for the Plaintiffs 
P.O. Box 586 

Durham, NC 27702 

Telephone: (919)-682-5691 

 



® " 

  

Williams, Boger, Grady, Davis & Tuttle, P 
   

— 

by: 
  

/" Martin B. McGee 
State Bar No.: 22198 

Attorneys for the Plaintiffs 

P.O. Box 2 

Kannapolis, NC 28081 

Telephone: (704)-932-3157 

Douglas E. Markham 

Texas State Bar No. 12986975 

Attorney for the Plaintiffs 

333 Clay Suite 4510 

Post Office Box 130923 

Houston, TX 77219-0923 

Telephone: (713) 655-8700 

Facsimile: (713) 655-8701 

  

 



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CERTIFICATE OF SERVICE 

I certify that I have this day hand delivered the foregoing Plaintiffs’ Response to Defendant- 
and Defendant Intervenors’ First Request for Production of Documents served to the following 
address: 

Ms. Tiare B. Smiley, Esq. 

Special Deputy Attorney General 

North Carolina Department of Justice 
114 W. Edenton St., Rm 337 
P.O. Box 629 

Raleigh, NC 27602 

Phone # (919) 716-6900 

This the 4" day of October, 1999 

  
  

Robinson O. Everett 

Attorney for the Plaintiffs 

 



  

Response to 

Request for Production #6 

 



  

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JOHN L. SANDERS 

1107 SOURWOOD DRIVE 

CHAPEL HILL, NORTH CAROLINA 27514-4914 

To: Robinson 0. Everett, Esquire 

From: John Sande 

Date: 22 Septem 999 

Subject: Congressional districting contest rules, 1997 

Here are the rules that you sent me for use in 
judging the entries in the congressional districting con- 
test "In 1997. 

Enclosed also is a statement that I issued at the 
time of the announcment of the results of the contest. 

These documents are from the file that I created 
at the time of the contest and that is still in my 
possession. 

 



EVERCTT GASKINS/DURHAM 
T 

9-582-5469 Jan oe 16:06 No.005 P.01 

CBE EAR, Sa, 

A.0. EVERETT (1878.1971) 
KATHERINE R. EVERETT (1821-1992) 
ROBINSON Q. EVERETT 
JAWN T, BATTISTE 
SANDRA @, HERRING , : : TEL $19) asa 103 

: 1919) 383.241. 

OF COUNSEL 

ROBERT 0. HOLLEMAN 

    

  

  

  

FAX NUMBER: | 162-p45¢ 

Number of pages transmitted: Cover page plus 

  

  

Deseriprion of document 
  

  

  
  

  

  

  

  From: 4 
- Nd 

This facsimile sontgins PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the 
addresses named above. [ff vou are not the intended recipient of this facsimile, or the employee or agent 
responsible for delivering it to the intended recipient, vou are hereby notified that any dissemination or copying 
of this facsimile is strictly prohibited. If you have received this faczimile in error please notity us ramediately by taphons and retum the original facsimile to us at the above address via the United States Postal Service. 
Thank you, 

  

 



  

‘EVERETT GASKINS/DURHAM "a 

AMERICANS FOR THE DEFENSE OF CONSTITUTIONAL RIGHTS 
301 West Main Street 

Suite 300 
Durham, North Carolina 27701 

Telephone: (919) 685-9659 Fax: (919) 682-5469 

REDISTRICTING CONTEST 

Purpose of Contest: To determine whether one or more geographically compact 
majority-black congressional districts can be drawn in North Carolina. 

Definitions: 
1) A "majority-black" congressional district is a district which contains within its 

boundaries one-twelfth of the total population of North Carolina, as shown by the 1990 
census, and of which more than half of its total population is composed of African- 
Americans, as shown by the 1990 census. 

2) A "geographically compact" congressional district is a district of which all parts 
are contiguous and which is "geographically compact" within the meaning of the Supreme 
Court's decisions in Shaw v. Reno, 509 U.S. 630 (1993), and Shaw v. Hunt, 116 S.Ct. 1894 
(1996). 

Sponsor: Americans for the Defense of Constitutional Rights (ADCR), a North 
Carolina non-profit corporation. 

Eligible Contestants: Any citizen or resident of North Carolina, except officers or 
directors of ADCR, may participate in the competition. Legislators and public officials 
of the State are fully eligible to compete. 

Entries: No more than five entries may be submitted by each contestant, and the person 
submitting an entry must be identified by name and address. An entry may be prepared 
by use of the public access computer of the General Assembly in Raleigh ot by use of 
any other computer(s) that provide(s) adequate access to population data and census 
blocks information. An entry should contain a map showing the proposed majority-black 
district or districts and sufficient census information to show that more than half of the 
total population of each proposed district is African-American. 

Place and Time for Submission: To be considered, an entry must be received by 
February 10, 1997. Each entry should be mailed or hand-delivered to Americans for the 
Defense of Constitutional Rights, 301 West Main Street, Suite 300, Durham, North 
Carolina 27701. 

  

Jan we 16:06 No.005 P.02



   EVERETT GASKINS/DURHAM 'o® Jan Ea 16:06 No.00S5S P.03 

Prizes: First prize - $2,000.00 
Second prize ~~ $1,000.00 
Third prize —- $ 500.00 

Contest Judge: The contest judge is Professor Emeritus John L. Sanders, who holds 
A.B. and J.D. degrees from the University of North Carolina; Professor Sanders served 
38 years on the UN.C. Faculty, of which 33 years were with the Institute of Government 
-+ 25 years as its Director -- and five years as the University’s Vice President for 
Planning. From 1957 to 1985, Professor Sanders studied legislative representation in 
North Carolina and frequently advised the General Assembly on this and other topics, 
He has written extensively on legislative representation and on many other aspects of 
state and local government. Professor Sanders is serving as contest judge on a pro bono 
basis, but he may, at his own discretion, obtain such technical assistance as he believes 
will be helpful to him in judging the contest. The decision by Professor Sanders as 
contest judge will be final and is expected to be rendered on or before February 24, 
1997. 

Rules: 

1) The first prize of $2,000.00 will be given to the contestant who submits an 
entry showing two proposed majority-black congressional districts which are each 
geographically compact within the meaning of the Supreme Court’s Shaw opinions and 
are each totally separate from the other; ie, the district boundaries may touch but they 
may not overlap. If two contestants submit such an entry showing two such majority- 
black districts which are geographically compact, the prize will be awarded to the 
contestant whose entry in the judge's opinion best attains the goal of compactness. If 
two entries are identical, the prize will be awarded for the entry first received; 

2) If the first prize is awarded, no second prize will be awarded. If no contestant 
qualifies for the first prize, the second prize of $1,000.00 will be awarded to the 
contestant who has submitted an entry showing one majority-black congressional district 
which in the judge’s opinion is the most geographically compact of those submitted; 

3) If the first or second prize is awarded, no third prize will be awarded. 
Therefore, the third prize will be awarded only as a consolation prize and only if no 
entry received shows a proposed majority-black congressional district which in the judge's 
opinion is geographically compact. The recipient of the third prize will be the person 
whose entry contains a majority-black congressional district which in the judge's opinion 
comes closest to attaining geographical compactness. 

 



   EVERETT GASKINS/DURHAM Tg ce oee Jan ve 16:07 No.005 P.04 

  

americans for the Defensa of Constitutional Rights, Inc., 

(ADCR) is a non-profit corporation organized under the laws of 

North Caroline by the five original plaintiffs in Shaw v. Reno, 

509 U.S. 630, 113 $.Ct, 2816 (1993). Because of their faith in 

the values of the Equal Protection Clause and thelr concern that 

racial garrymandars and racial quotas are endangering those 

values and exacerbating, rathar than reducing, racial divisions, 

these five citizens created ADCR. Among ANCR’/a missions are to 

inform the public about some of the odious practices which 

currently threaten tha goal of a “color blind society: urge 

logielatore and public officiale to enact laws and issue decrees 

that will meet theca threats) and, ac a last resort, te ancoeurage 

or even institute litigation to eliminate procedures, 

methodology, and sccial structures which tend to polarize our 

citizens along racial linex. 

 



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2/22/97 

  

CONGRESSIONAL DISTRICT PROPOSALS: EVALUATION PROCESS 

l. Nine district plans were submitted by a total of five 

persons. Each plan was examined in the following ways. 

2. Does the proposed district contain appoximately one- 

twelfth of the state's 1990 total population of 

6,628,637, or 552,386 people? Among the nine plans 

submitted, the maximum deviation from 552,386 was .67 

of one per cent. No further consideration was given 

to this factor, since all nine plans were deemed to 

be acceptable by that measure. 

3. Does the proposed district contain a majority of black 

residents? All nine of the districts evaluated were 

found to contain over 50 per cent black residents. 

No further consideration was given to percentages of 

black population, since all nine plans were deemed to 

be acceptable by that-measure. 

4. One plan was rejected for extreme lack of compactness. 

It extended from Greensboro southwesterly to Charlotte 

and thence southeasterly to Sampson County. 

 



wh 

The remaining eight plans were submitted to the Legis-— 

lative Automated Systems Division of the General Assem- 

bly, which analyzed them for accuracy of population 

data and prepared large-scale maps that enabled ready 

comparison of seven of the plans. (The Division was 

unable to process the data provided by the consultant 

to the League of Women Voters, so that entry was evalu- 

ated on the basis of the population data and a small 

map provided by the consultant.) 

The Legislative Automated Data Systems Division cal- 

culated the area (in square miles) and the perimeter 

(in miles) of each of the seven proposed districts 

and applied to each district the Schwarzberg test 

to determine relative compactness. This test is 

applied by determining the shortest perimenter that 

would enclose the area of each proposed district (a 

circle) and dividing the actual perimenter by that 

shorter, eircular perimenter. The result is a ratio; 

the nearer that ratio is to 1.0, the more compact is 

the district. That test was used to determine the 

"one majority black congressional district which in 

the judge's opinion is the most geographically com- 

pact of those submitted." 

John Sanders  



0 we 

  

2/22/97 

C ONGRESSIONAL DISTRICTING CONTEST WINNER ANNOUNCED 

On January 6, Americans for the Defense of Constitutional 

Rights, a Durham-based nonprofit foundation, announced a con- 

test to draw one or two geograpically compact, majority- 

black congressional districts for North Carolina, each con- 

taining one-twelfth of the state's 1990 population. 

A first prize of $2,000 was offered for the entry that 

showed two districts meeting those standards. If no entry 

met that condition, a second prize of $1,000 was offered 

for the "entry showing one majority-black congressional dis- 

trict which = in the judge's opinion is the most geograpi- 

cally compact of those submitted." If no first or second . 

prize was awarded, a third prize of $500 was offered for 

the "entry [that] contains a majority-black congressional 

district which in the judge's opinion comes closest to 

attaining geograpical compactness." 

Twelve persons (including a consultant who submitted 

an entry on behalf of the North Carolina League of Women 

Voters) submitted one or more plans each. 

No one proposed two acceptable compact and majority- 

black districts, so no first prize will be awarded. 

Six of the entries were found not to be responsive 

to the request for proposals because they did not offer 

plans for congressional districts. Instead, they proposed 

 



  

ae |g 

other schemes of election, such as at-large election of all 

twelve members of Congress from the entire state, which federal 

law does not permit. One entry was rejected because the dis- 

tricts it described were composed to contain majorities of 

"minority populations" and thus it was not responsive to 

the call for digeriers containing black majorities. 

Nine plans remained, the work of five contestants. One 

of those plans was found to be so obviously noncompact that 

it was rejected. The remaining eight plans, submitted by 

five contestants, were evaluated according to the procedures 

outlined in the attached memo. 

Each of the eight districts contains one-twelfth of the 

state's 1990 population. Each contains more than 50 per cent 

black population. Each consists of contiguous territory. All 

begin with the City of Durham on the west and range eastward 

along the Virginia line in quest of the ideal of 552,386 

residents according to the 1990 census. 

On the basis of the Schwarzburg test, a mathematical 

measure of district compactness explained in the attached 

memo, Plan 1b submitted by Jack Daly of Raleigh is adjudged 

to be "the most geographically compact of those [plans] 

submitted" and is the winner of the second prize of $1,000. 

That district has a Schwarzburg ratio of 1.85 and a 1990 

black majority of 50.18 per cent. (Mr. Daly also submitted 

 



00 we 

  

the second most compact district plan, with a Schwarzburg 

ratio of 1.87 and a majority black population of 50.08 

per cent. 

Qn 
John S anders 

 



  

at  -» 

2/22/97 

CONGRESSIONAL DISTRICT PROPOSALS: EVALUATION PROCESS 

Nine district plans were submitted by a total of five 

persons. Each plan was examined in the following ways. 

Does the proposed district contain appoximately one- 

twelfth of the state's 1990 total population of 

6,628,637, or 552,386. people? Among the nine plans 

submitted, the maximum deviation from 552,386 was .67 

of one per cent. No further consideration was given 

to this factor, since all nine plans were deemed to 

be acceptable by that measure. 

Does the proposed district contain a majority of black 

residents? All nine of the districts evaluated were 

found to contain over 50 per cent black residents. 

No further consideration was given to percentages of 

black population, since all nine plans ware deevied to 

be acceptable by that measure. 

One plan was rejected for extreme lack of compactness. 

It extended from Greensboro southwesterly to Charlotte 

and thence southeasterly to Sampson County. 

 



» oe 

The remaining eight plans were submitted to the Legis- 

lative Automated Systems Division of the General Assem- 

bly, which analyzed them for accuracy of population 

data and prepared large-scale maps that enabled ready 

comparison of seven of the plans. (The Division was 

unable to Process the data provided by the consultant 

to the League of Women Voters, so that entry was evalis 

ated on the basis of the population data and a small 

map provided by the consultant.) 

The Legislative Automated Data Systems Division cal- 

culated the area (in square miles) and the perimeter 

(in miles) of each of the seven proposed districts 

and applied to each district the Schwarzberg test 

to determine relative compactness. This test is 

applied by determining the shortest perimenter that 

would enclose the area of each proposed district (a 

circle) and dividing .the actual perimenter by that 

shorter, eircular perimenter. The result is a ratio; 

the nearer that ratio is to 1.0, the more compact is 

the district. That test was used to determine the 

"one majority black congressional district which in 

the judge's opinion is the most geographically com- 

pact of those submitted." 

John Sanders 

TI TE A  



2/22/97 

  

CONGRESSIONAL DISTRICT PLANS COMPARED 

  

Total Percentage Sq. Mi. Actual Circular Schwarz- 
Author District Population Black Area Perimeter Perimeter berg Test 

Byrd, Tricia Turner la 552,576 51.10 5,754 623 269 2.32 

Byrd, Tricia Turner 1b 552,226 51.04 5,783 581 270 2.16 

Daly, Jack la 551,634 50.22 7,953 647 316 2.05 

Daly, Jack 1b 551,214 50.18 7,893 584 315 1.85 3 

Daly, Jack lc 552,222 50.08 7,785 586 313 1.87 

Henderson, Diane (NCLWV) 1. 553,528 51.83 

McDowell, Valecia 1 556,088 53.17 6,474 1,067 285 3.74 

Robbins, Zachary L. 1 551,069 54.43 6,234 631 280 2.25 

  

Ideal (1/12) 552,386 

 



2/22/97 

  

CONGRESSIONAL DISTRICT PLANS COMPARED 

  

Total Percentage Sq. Mi. Actual Circular Schwarz- 

Author District Population Black Area Perimeter Perimeter berg, Test 

Byrd, Tricia Turner la 552,576 51.10 5,754 623 269 2.32 

Byrd, Tricia Turner 1b 352,226 51.04 5.783 581 270 2.16 

Daly, Jack la 551,634 50.22 7,953 647 316 2.05 

Daly, Jack 1b 551,214 50.18 7,893 584 315 1.85 3 

Daly, Jack 1c 552,222 50.08 7,785 586 313 1.87 

Henderson, Diane (NCLWV) 1 553,528 51.83 

McDowell, Valecia 1 556,088 53.17 6,474 1,067 285 3.74 

Robbins, Zachary L. 1 551,069 54.43 6,234 631 280 2.25 

  

Ideal (1/12) 552,386 

 



  

Ro an L 
JOHN L. SANDERS 

1107 SourwooD Drive 

CHAPEL HILL. NORTH CAROLINA 27814 

. 24 February 1997 

Mr. Zachary L. Robbins 

213 White Hall 
East Carolina University 
Greenville, North Carolina 27858 

Dear Mr. Robbins: 

Thank you for your entry in the contest to design one 
Or two compact, majority-black congressional districts for 
North Carolina, sponsored by Americans for the Defense of 
Constitutional Rights. 

The decision was announced today. The enclosed press 
release and accompanying information explain the outcome 
of the contest and how it was reached. 

Yours, incidentally, was the only entry of the twelve 
that proposed two majority-black districts. Your southern 
district was sufficiently non-compact that it was not 
acceptable and was not analyzed in the same manner as the 
eight districts represented in the attached table. Your 
northern district (which I have designated as District 1) 
was one of the eight analyzed. 

Your map, together with the other seven that were 
analyzed, has been turned over to the General Assembly for 
its information and potential use in designing the new 
districts. ig 

Sincerely yours, 

Reson 

hn Sanders 

cc: Robinson 0. Everett, Esquire 

 



wh o® 
JOHN L. SANDERS 

  

1107 S8OURwWOOD DRIVE 

CHAPEL HiLL. NORTH CAROLINA 27514 

24 February 1997 

Jack Daly 

Executive Director 

North Carolina Fund for Individual Rights, Inc. 
P.. 0. Box 31784 

Raleigh, North Carolina 27622 

Dear Mr. Daly: 

Thank you for your entries in the contest to design 
one or two compact, majority-black congressional districts 
for North Carolina, sponsored by Americans for the Defense 
of Constitutional Rights. 

Congratulations on having won the second prize in the 
contest. I gave you in Raleigh the press release and other 
information explaining how the decision was reached. 

Your maps, together with the other six that were 
analyzed, have been turned over to the General Assembly for 
its information and use in designing the new districts. 

Sincerely yours, 

re ie 

ohn Sanders 

cc: Robinson O. Everett, Esquire 

 



we oo’ 
JOHN L. SANDERS 

1107 SouRwoOD DRIVE 

CHAPEL HiLL. NORTH CAROLINA 27514 

+ 24 February 1997 

Valecia McDowell 

3202 Myra Street, Apt. K 

Durham, North Carolina 27707 

Dear Ms. McDowell: 

Thank you for your entry in the contest to design one 
or two compact, majority-black congressional districts for 
North Carolina, sponsored by Americans for the Defense of 
Constitutional Rights. 

The decision was accounced today. The enclosed press 
release and accompanying information explain the outcome 
of the contest and how it was reached. 

Your map, together with the other seven that were 
analyzed, has been turned over to the General Assembly for 
its information and use in designing the new districts. 

Sincerely yours, 

Seda 

hn Sanders 

cc: Robinsion O. Everett, Esquire 

 



  

    

  

oo’ 

  

we 

CHAPEL HILL, NORTH CAROLINA 27814 

JOHN L. SANDERS 

1107 S8ourRwooOD DRivE 

. 24 February 1997 

Tricia Turner Byrd 

6012 Carriage Oaks Drive 
Charlotte, North Carolina 28262 

Thank you for your entries in the contest to design 
one or two compact, majority-black congressional districts 
for North Carolina, sponsored by Americans for the Defense 
of Constitutional Rights. 

The decision was announced today. The enclosed press 
release and accompanying information explain the outcome 
of the contest and how it was reached. 

Your maps, together with the other six that were 
analyzed, have been turned over to the General Assembly 
for its information and use in designing the new districts. 

Sincerely yours, 

Do 
n Sanders 

cc: Robinson 0. Everette, Esquire 

 



  

   oP 

  

we 

CHAPEL HILL. NORTH CAROLINA 27514 

JOHN L. SANDERS 

1107 SsouRwooOD DRIVE 

24 February 1997 

Bernadette Parker 

President 

League of Women Voters of North Carolina 
Suite 311 
3900 Barrett Drive 

Raleigh, North Carolina 27609-6614 

Dear Ms. Parker: 

Thank you for the League of Women Voters' entry in 
the contest to design one or two compact, majority-black 
congressional districts for North Carolina. 

The desision was announced today. The enclosed 
press release and accompanying information explain the 
outcome and how it was reached. The data processors 
on the General Assembly staff never were able to import 
the data on your plan into their system, so I did not 
have two factors, area and perimenter length, that were 
available with respect to the other plans analyzed. I 
do not think that affected the outcome of the contest, 
however. 

Your map, together with the other seven that were 
analyzed, has been turned over to the General Assembly 
for its information and use in designing the new districts. 

Sincerely yours, 

A 
hn Sanders 

cc: Robinson 0. Everett, Esquire 
Diane Henderson 

 



  

oe we 
JOHN L. SANDERS 

1107 SOoURWOOD DRIVE 

CHAPEL HILL. NORTH CAROLINA 27314 

22 February 1997 

Eddie Teachey 

1353 River Dreams Road 

Raleigh, North Carolina 27610-8237 

Dear Mr. Teachey: 

Thank you for your entry in the contest to design 

one or two majority-black, compact congressional districts 

for North Carolina, sponsored by Americans for the Defense 

of Constitutional Rights. 

The terms of the contest make it clear that it calls 

for one or two districts in which a majority of the resi- 

dents are black and which are geographically compact. 

Your entry shows the "minority population' for the counties 
and census tracts that compose your two proposed districts, 

but it does not show the black percentages of their popu- 

lations. Consequently, I am unable to determine from your 

data whether either of your proposed districts meets the 

terms of the contest. Therefore, I find that your entry is 

not responsive to the invitation for proposals. 

Sincerely yours, 

| TCC. 

hn Sanders 

cc: Robinson 0. Everett, Esquire 

 



  

o® " 
JOHN L. SANDERS 

1107 SOURWOOD DRIVE 

CHAPEL HiLL. NORTH CAROLINA 27514 

--22 February 1997 

J. P. George 

705 South First Street 

Smithfield, North Carolina 27577 

Dear Mr. George: 

Thank you for your entry in the contest to design 

one or two compact, majority-black congressional districts 

for North Carolina, sponsored by Americans for the Defense 

of Constitutional Rights. 

Your proposal does not describe one or more congress- 

ional districts, although federal law requires that there 

be as many districts as there are members to be elected 

from the state, and therefore I find that it is not re- 

sponsive to the invitation for proposals. 

Sincerely yours, 

oe ASA ty 

ohn Sanders 

cc: Robinson 0. Everett, Esquire 

 



o® "wh 
JOHN L. SANDERS 

1107 SOURWOOD DRivE 

CHAPEL HILL. NORTH CAROLINA 27314 

22 February 1997 

Leland O. Scott, Jr. 

608 South Caswell Street 

LaGrange, North Carolina 28551 

Dear Mr. Scott: 

Thank you for your entry in the contest to design 
one or two majority-black, compact congressional districts 
for North Carolina, sponsored by Americans for the Defense 
of Constitutional Rights. 

Since your proposal does not describe one or more con- 
gressional districts, although federal law requires as many 
districts as there are members to be elected, I find that 
it is not responsive to the invitation for proposals. 

Sincerely yours, 

lesen. 
ohn Sanders 

Robinson O. Everett, Esquire 

 



      

o® ot 
JOHN L. SANDERS 

1107 SourRwoOD DRIVE 

CHAPEL HiLL, NORTH CAROLINA 27514 

"22 February 1997 

Emmett N. Bailey, Jr. 

609 Soring Valley Road 
Henderson, North Carolina 27536 

Dear Mr. Bailey: 

Thank you for your entry in the contest to design 

one or two compact, majority-black congressional districts 

for North Carolina, sponsored by Americans for the Defense 

of Constitutional Rights. 

Since your proposal does not describe one or more 

congressional districts, I find that it is not responsive 

to the invitation for proposals. 

Sincerely yours, 

IR 
ohn Sanders 

cc: Robinson O. Everett, Esquire 

 



o® wh 
JOHN L. SANDERS 

  

1107 SOURWOOD DRIVE 

CHAPEL HILL. NORTH CAROLINA 27514 

22 February 1997 

Wayne Taylor 

2623 Kirk Road 

Durham, North Carolina 27705 

Dear Mr. Taylor: 

Thank you for your entry in the contest to design 
one or two compact, majority-black congressional districts 
for North Carolina, sponsored by Americans for the Defense 
of Constitutional Rights. 

Since your proposal merely depicts twelve arbitrarily 
drawn districts, withour information as to their populations, 
I find that it is not responsive to the invitation for pro- 
posals. 

Sincerely yours, 

st Las 
hn Sanders 

cc: Robionson O. Everett, Esquire 

 



  

ot dt 
JOHN L. SANDERS 

1107 SourRwoOOD DRIVE 

CHAPEL HILL. NORTH CAROLINA 27514 

22 February 1997 

John D. B. Baston 

Aot. 10D 

LaSalle Street 

Durham, North Carolina 27705-3620 

Dear Mr. Baston: 

Thank you for your entry in the contest to design 
one or two compact, majority-black congressional districts 
for North Carolina, sponsored by Americans for the Defense 
of Constitutional Rights. 

Since your proposal does not describe one or more con- 
gressional districts and federal law requires that there 
be as many districts as there are congressional seats to be 
filled by the state, I find that it is not responsive to the 
invitation for proposals. 

Sincerely yours, 

eOL.S 

hn Sanders 

cc: Robinson 0. Everett, .Esquire 

 



  

oh oe 
JOHN L. SANDERS 

1107 SourRwoOD DRive 

CHAPEL HILL. NORTH CAROLINA 27514 

+22 February 1997 

Randy Crow 

2119 Gloucester Place 

Wilmington, North Carolina 28403 

Dear Mr. Crow: 

Thank you for your entry in the contest to design 
one or two compact, majority-black congressional districts 

for North Carolina, sponsored by Americans for the Defense 

of Constitutional Rights. 

Since your proposal does not describe your proposed 

congressional districts with necessary information about 

their populations and seems to contemplate assembling 

districts from non-contiguous areas, I find that it is not 

responisve to the invitation for proposals. 

Sincerely yours, 

SE \ NC 
ohn Sanders 

CC: Robinson 0. Everett, Esquire 

 



  

Response to 

Request for Production #8 

 



  

  

  
  

    League of Women Voters of North Carolina 
Redistricting Flan based on 1990 Csnaua Data 
Jariuary 1997 - 

      

  

 



  

LWVNC-1997 od 

‘RATIONALE FOR REDISTRICTING PLAN 

January 1997 

The League of Women Voters of North Carolina 1997 Redistricting Plan is based on the plan submitted by the League to the General Assembly and the Department of Justice in 1991 and 1992 but with modifications to provide a “majority-minority” district of over 50% black population. In 1992 we had argued that since a person could win a primary election with 40% of the vote, a minority candidate would have an excellent chance of election in a district having a black population greater than 40%, and had proposed two such districts. 

The African American population of North Carolina is not concentrated in any particular district, and it is very difficult to create a majority minority district that also follows good demographic principles like maintaining minor civil divisions (counties, cities and towns) and respecting geographic realities, as well as being compact and contiguous. 

In developing this plan, we have tried not to divide counties unless necessary to balance populations. Most divided counties are split between two districts, but in three cases it was necessary to divide counties into three districts in order to have a relatively compact district with enough minority voters to achieve slightly more than 50%. District 3, in addition, has a 32+% African American population, although not a majority minority district. 

Other considerations were to ensure adequate representation for various special interests, e.g. coastal interests — marine fisheries, tourism, beach protection — and the state’s military establishments, making sure that Ft. Bragg, Seymour Johnson AF B, Camp Lejeune, and the Army Corps of Engineers sites were not all included in a single district. Similarly, there are multiple districts representing mountainous parts of the state, and several fairly compact more-or-less urban districts. No partisan political information — voting registration, incumbent Congressional representation — was used. Since there is no requirement in the federal or state Constitution for residency in the Congressional district one represents, there is nothing in this plan to preclude the present incumbents’ running in a different district. 

The plan submitted in 1992 was prepared using an intermediate level of data aggregation which the General Assembly’s data processing personnel were not able to relate to their data bases. This time, we have used the Census Block-level data (SUMLEV=75 0, in a database of about 28 MB containing over 150,000 records). For the divided counties, we can provide DBF format data files compressed onto two floppy disks rather than printing the detailed lists, which would run to hundreds of pages. Mapinfo Professional 4.1 Desktop Mapping software was used for the work. (In 1992 we used version 2.0 of Mapinfo). 

All data used by LWVNC come from the Census of Population and Housing, 1990: Public Law (P.L.) 94-171 Data on CD-ROM (North Carolina) [machine readable data files] / prepared by the Bureau of the Census, — Washington: The Bureau [producer and distributor], 1991. There is generally no information on voting precincts in the North Carolina data, so it is difficult to try to avoid dividing these. 

If there are questions about these materials, please contact Diane Henderson, Redistricting consultant to the LWVNC Board. Phone 919-261-2689; fax 919-261-7437 ; e-mail, nhendrsn@jinterpath.com. 

 



we 

Total Variation Percent Minority Percent District Perimet 
population from desired variation Popu- Minority Size (sq. er 

LWVNC-1997 January 1997 

District Popu- 

lation 
O
C
O
o
O
N
O
T
O
P
E
L
W
N
 ==
 

553,528 
553,321 
552,654 
551,695 
552,395 
551,976 
551,142 
552,383 
553,178 
552,505 
551,473 
552,387 

number 

1142 
935 

268 
-691 

9 
-410 
-1244 

-3 
792 
119 
-913 

1 

from 

552386 

0.21% 

0.17% 

0.05% 

-0.13% 

0.00% 

-0.07% 

-0.23% 

0.00% 

0.14% 

0.02% 

-0.17% 

0.00% 

lation 

286,886 
141,889 
177,526 
120,141 
112,503 
125,246 
137,737 
144,097 
66,263 
88,863 
50,402 
29,276 

Popu- 

lation 

51.8% 

25.6% 

32.1% 

21.8% 

20.4% 

22.7% 

25.0% 

26.1% 

12.0% 

16.1% 

9.1% 

5.3% 

mi.) 

5,500 
11,180 
4,947 
2,386 
4,976 
1,894 
5,574 
477 

3,145 
3,528 
3,296 
6,581 

548.5 
662.6 
325.2 
246.6 
403.8 

258 
491.8 
119.6 
281.4 
333.4 
336.3 
409.3 

density 

101 
49 
112 
231 
111 
291 
99 

1158 
176 
157 
167 
84 

6,628,637 

Notes to the comparison statistics: 

1. The deviations from the desired number of 552,386 are quite small. Formerly, plus or minus 1% was 
considered permissible in redistricting, but with computers, we can do better. The maximum deviation 
here is -0.23% for District 7. All deviations in this plan are less than one-quarter of one percent, well 
within the permissible range. 

2. District size in square miles is derived from the region sizes by the mapping software. They are 
based on polygons that had to be drawn by hand due to lack of any closed figures in the map, and 
should be considered only approximations. The same approximation problem occurs with the 
perimeters; they are useful for comparison purposes, but not definitive. 

3. The population density was calculated primarily to show the extreme variations of density among 
different regions. The coastal plain, full of bays and estuaries and wetlands, is the most sparsely 
settled. Mountain areas have similar characteristics for different reasons. 

 



LWVNC 1997 Redistricting Plan » 

Counties and parts of Counties by District 

  

  

  

Black 

Total Popu- Popu- Percent 

County District lation lation Black 

BERTIE 1 20,388 12,531 61.46% 

Durham 1 91,916 59,724 64.98% 

EDGECOMBE 1 56,558 31,661 55.98% 

GATES 1 9,305 4,180 44.92% 

Granville 1 24,918 10,946 43.93% 

HALIFAX 1 55,516 27,586 49.69% 

HERTFORD 1 22,523 12,970 57.59% 

Martin 1 19,971 10,065 50.40% 

Nash 1 54,850 15,919 29.02% 

NORTHAMPTON 1 20,798 12,328 59.27% 

Pasquotank 1 19,458 9,730 50.01% 

Perquimans 1 6,480 2,702 41.70% 
Pitt 1 45,224 23.827 52.69% 

VANCE 1 38,892 17,512 45.03% 

WARREN: 1 17,265 9,847 57.03% 

Washington 1 6,173 3,663 59.34% 

Wilson 1 43,293 21,695 50.11% 

Totals, District 1 553,528 286,886 51.83% 

BEAUFORT 2 42,283 13,194 31.20% 

CAMDEN 2 5,904 1,481 25.08% 

CARTERET 2 52.656 4,385 8.34% 

CHOWAN 2 13,506 5,087 37.66% 

CRAVEN 2 81,613 21.116. 25.87% 

CURRITUCK 2 13,736 1,845 11.25% 

DARE 2 22,746 811 3.57% 

GREENE 2 15,384 6,521 42.39% 

HYDE 2 5,411 1.781 32.91% 

Johnston 2 17,091 2.273 13.30% 

JONES 2 9,414 3,677 39.06% 

LENOIR 2 57,274 22.539 - 30.35% 

Martin 2 5,107 1.121. 21.95% 

Onslow 2 5,071 697 13.74% 

PAMLICO 2 11.372 2,951 25.95% 

Pasquotank 2 11,840 1,853 - 15.85% 

Perquimans 2 3,967 724 18.25% 

Pitt 2 62,700 12,094 19.29% 

TYRRELL 2 3,856 1,543 40.02% 

Washington 2 7,824 2,703. 34.55% 

WAYNE 2 104,666 33,793 32.20% 

Totals, District 2 553,321 141,889 25.64% 

BLADEN 3 28,663 11,199 39.07% 

Cumberland 3 253,067 97,269 38.44% 

DUPLIN 3 39,995 13,2590 33.15% 

New Hanover 3 10,010 2,232 22.30% 

Onslow 3 144,767 29,111 20.11% 

January 1997 
Page 1 of 3 

 



  
Page 2 of 3 

LWVNC 1997 Redistricting Plan 

Counties and parts of Counties by District 

PENDER 

SAMPSON 

Totals, District 3 
  

Durham 

FRANKLIN 

Granville 

Johnston 

Nash 

Wake 

Wilson 

Totals, District 4 
  

Alamance 

CASWELL 

CHATHAM 

Durham 

Granville 

HARNETT 

LEE 

MOORE 

ORANGE 

PERSON 

Randolph 

Wake 

Totals, District 5 

R
O
E
 

R
O
E
 
E
O
E
 

R 
LR
G 

Re
 

  

Alamance 

Forsyth 

GUILFORD 

ROCKINGHAM 

STOKES 

Totals, District 6 
  

ANSON 

BRUNSWICK 

COLUMBUS 

Cumberland 

HOKE 

Mecklenburg 

New Hanover 

RICHMOND 

ROBESON 

SCOTLAND 

UNION 

. Totals, District 7 
  

Gaston 

Mecklenburg 

Totals, District 8 
  

3 
3 

EN
E 

SE
 

NE
 

[e
) 

BN 
e
)
I
N
e
)
 

Be
) 

I
e
)
 

N
N
N
N
N
N
N
N
N
N
N
 

(o
} 

28,855 
47,297 

552,654 

7,183 
36,414 
8,501 

64,215 
21,827 

390,787 
22,768 

551,695 

44,176 
20,693 
38,759 

82,736 
4,926 

67,822 
41,374 
59,013 
93,851 

30,180 

36,272 

32,593 
552,395 

64,037 
17,232 

347,420 
86,064 

37,223 

551,976 

23,474 
50,985 
49,587 
21,499 
22,856 

4,805 

110,274 

44,518 
105,179 
33,754 
84,211 

551,142 

89,472 
462,911 
552,383 

8,770 

15,686 
177,526 

662 

12,843 
2,010 

12,116 
8,223 

81,086 
3,201 

120,141 

7,849 
8,436 
8,845 

16,268 
1,953 

15,315 
9,401 

10,882 
14,893 

9,106 

2,584 

6,971 
112,503 

12,973 
1,001 

91,655 
17,548 
12,069 

125,246 

11,106 
9,211 

15,181 
5,733 

9,878 
106 

21,865 

12,869 
26,185 
12,176 
13,427 

137,737 

14,820 

129,277 
144,097 

30.39% 

33.16% 

32.12% 

9.22% 

35.27% 
23.64% 
18.87% 

37.67% 
20.75% 
14.06% 

21.78% 

17.77% 
40.77% 
22.82% 
19.66% 
39.65% 
22.58% 
22.72% 
18.44% 
15.87% 

30.17% 

7.12% 
21.39% 

20.37% 

20.26% 

5.81% 
26.38% 

20.39% 

5.56% 

22.69% 

47.31% 
18.07% 
30.61% 

26.67% 
43.22% 
2.21% 

19.83% 

28.91% 
24.90% 
36.07% 
15.94% 
24.99% 

16.56% 
27.93% 

26.09% 

January 1997 

 



A 1997 Redistricting Plan i 

Counties and parts of Counties by District 

  

  

  

  

CABARRUS 9 98,935 12,853 12.99% 

DAVIDSON 9 126,677 12,314 9.72% 

DAVIE 9 27,859 2,482 8.91% 

Mecklenburg 9 43,717 5085 11.63% 

MONTGOMERY 9 23,346 6,001 25.70% 

Randolph 9 70,274 3,783 5.38% 

ROWAN 9 110,605 17.773 16.07% 

STANLY 9 51,765 5972 11.54% 

Totals, District 9 553,178 66,263 11.98% 

ALEXANDER 10 27,544 1,673 6.07% 

ALLEGHANY 10 9,590 177 1.85% 

ASHE 10 22,209 144 0.65% 

Forsyth 10 248,646 65,101 26.18% 

IREDELL 40 92,931 14,869 16.00% 

SURRY 10 61,704 2,780 4.51% 

WILKES 10 59,393 2,824 4.75% 

YADKIN 10 30,488 1,295 4.25% 

Totals, District 10 552,505 88,863 16.08% 

AVERY 11 14,867 158 1.06% 

BURKE 11 75,744 5,178 6.84% 

CALDWELL 11 70,709 3,881 5.49% 

CATAWBA 11 118,412 10,689 9.03% 

CLEVELAND 11 84,714 17,741 20.94% 

Gaston 11 85,621 7,856 9.18% 

LINCOLN 11 50,319 4,108 8.16% 

Mitchell 11 14,135 23 0.16% 

WATAUGA 11 36,952 768 2.08% 

Totals, District 11 : 551,473 50,402 9.14% 

BUNCOMBE 12 174,821 14,336 8.20% 

CHEROKEE 12 20,170 361 1.79% 

CLAY 12 7.155 41 0.57% 

GRAHAM 12 7,196 1 0.01% 

HAYWOOD 12 46,942 648 1.38% 

HENDERSON 12 69,285 2,361 3.41% 

JACKSON 12 26,846 425 1.58% 

MACON 12 23,499 385 1.64% 

MADISON 12 16,953 136 0.80% 

MCDOWELL 12 35,681 1,479 4.15% 

Mitchell 12 298 0 0.00% 

POLK : 12 14,416 1,053 7.30% 

RUTHERFORD 12 56,918 6,514 11.44% 

SWAIN 12 11,268 196 1.74% 

- TRANSYLVANIA 12 25,520 1,189 4.66% 

YANCEY 12 15,419 151 0.98% 

Totals, District 12 552,387 29,276 5.30% 
  

Names of divided Counties appear in bold type. 

January 1997 
Page 3 of 3 

 



ne Alphabetic Listing of Counties we 

LWVNC 1997 Plan 

TOTAL BLACK 

POPU- POPU- 

COUNTY NAME District LATION LATION % BLACK 

Alamance 5 44,176 7849 17.77% 

Alamance 64,037 12,973 20.26% 

ALEXANDER 27,544 1,673 40.77% 

ALLEGHANY 9,590 177 9.03% 

ANSON 23,474 11,106 47.31% 

ASHE 22,209 144 22.82% 

AVERY 14,867 158 25.87% 

BEAUFORT 42,283 13,194 49.69% 

BERTIE 20,388 12,531 61.46% 

BLADEN 28,663 11,199 39.07% 

BRUNSWICK 50,985 9,211 18.07% 

BUNCOMBE 174,821 14,336 19.66% 

BURKE 75,744 5178 38.44% 

CABARRUS 98,935 12,853 12.99% 

CALDWELL 70,709 3,881 26.67% 

CAMDEN 5,904 1,481 22.58% 

CARTERET 52,556 4,385 1.38% 

CASWELL 20,693 8,436 40.77% 

CATAWBA 118,412 10,689 11.25% 

CHATHAM 38,759 8,845 22.82% 

CHEROKEE 20,170 361 55.98% 

CHOWAN 13,506 5,087 3.41% 

CLAY 7,155 41 5.81% 

CLEVELAND 84,714 17,741 3.57% 

COLUMBUS 49,587 15,181. 30.61% 

CRAVEN 81,613 21.116. © 57.59% 

Cumberland 253,067 97,269 38.44% 

Cumberland 21,499 5,733. 26.67% 

CURRITUCK 13,736 1,545 43.22% 

DARE 22,746 811 32.91% 

DAVIDSON 126,677 12,314 9.72% 

DAVIE 27,859 2,482 8.91% 

DUPLIN 39,995 13,250 33.15% 

Durham 91,916 59,724 64.98% 

Durham 7,183 662 9.22% 

Durham 82,736 16,268 19.66% 

EDGECOMBE 56,558 31,661 55.98% 

Forsyth 248,646 65,101 1.79% 

Forsyth 17,232 1,001 5.81% 

FRANKLIN 36,414 12,843 35.27% 

Gaston 85,621 7,856 9.72% 

Gaston 89,472 14,820 16.56% 

. GATES 9,305 4,180 1.85% 

GRAHAM 7,196 1 26.18% 

Granville 24,918 10,946 47.31% 

Granville 8,501 2,010 19.83% 

Granville 4,926 1,053 39.65% 

GREENE 15,384 6,521 16.00% N
O
B
 

A
T
 
2
0
g
 

O
R
 

W
O
O
N
N
N
®
O
N
N
 

Page 1 of 3 January 1997  



* 

: Alphabetic Listing of Counties » 

LWVNC 1997 Plan 

  

GUILFORD 6 347,420 91,655 26.38% 
HALIFAX 3 55,516 27,586 0.65% 
HARNETT 5 67,822 15,3156 22.58% 
HAYWOOD 12 46,942 648 35.27% 
HENDERSON 12 69,285 2,361 16.56% 
HERTFORD 1 22,523 12,970 1.06% 
HOKE 7 22,856 0,878 43.22% 

HYDE 2 5,411 1,781 1.58% 
IREDELL 10 92,931 14,869 37.66% 

JACKSON 12 26,846 425 9.18% 
Johnston 2 17,091 2273 13.30% 
Johnston #4 64,215 12,116 59.27% 

JONES 2 9,414 3,677 18.87% 
LEE 5 41,374 9,401 22.72% 

LENOIR 2 57,274 22,539 39.06% 
LINCOLN 11 50,319 4,108 8.16% 
MACON 12 23,499 385 1.64% 
MADISON 12 16,953 136 0.80% 
Martin 1 19,971 10,065 50.40% 
Martin 2 5,107 1.121. 21.95% 
MCDOWELL 12 35,681 1,479 4.15% 
Mecklenburg 7 4,805 106 2.21% 

Mecklenburg 8 462,911 129.277 27.93% 

Mecklenburg 9 43,717 5085 11.63% 

Mitchell 11 14,135 23 0.16% 

Mitchell 12 298 0 0.00% 
MONTGOMERY 9 23,346 6,001 25.70% 

MOORE 5 59,013 10,882 18.44% 

Nash 1 54,850 15,919 29.02% 
Nash 4 21,827 8,223 37.67% 
New Hanover 3 10,010 2232 22.30% 

New Hanover 7 110,274 . 21.865 19.83% 

NORTHAMPTON 1 20,798 12,328 39.07% 
Onslow 2 5,071 697 39.35% 

Onslow 3 144,767 20,111 20.11% 
ORANGE 5 93,851 14,893 15.87% 

PAMLICO 2 11,372 2,951 25.95% 

Pasquotank 1 19,458 9,730 50.01% 

Pasquotank 2 11,840 1,853 15.65% 

PENDER 3 28,855 8,770 30.39% 
Perquimans 1 6,480 2,702 41.70% 

Perquimans 2 3,967 724 18.25% 
PERSON 5 30,180 9,106 30.17% 
Pitt 1 45,224 23,827 52.69% 
Pitt 2 62,700 12,094 19.29% 
POLK 12 14,416 1,053 7.30% 
Randolph 5 36,272 2,584 7.12% 

Randolph 9 70,274 3,783 5.38% 

RICHMOND / J 44,518 12,869 28.91% 
ROBESON 1 105,179 26,185 24.90% 

ROCKINGHAM 6 86,064 17,548 20.39% 

Page 2 of 3 January 1997 

 



Alphabetic Listing of Counties we 

LWVNC 1997 Plan 

ROWAN 110,605 17,773 . 16.07% 

RUTHERFORD 56,918 6,514 . 11.44% 

SAMPSON 47,297 15,686 33.16% 

SCOTLAND 33,754 12,176 36.07% 

STANLY 51,765 5972 11.54% 

STOKES 37,223 2,069 5.56% 

SURRY 61,704 2,780 4.51% 

SWAIN 11,268 196 1.74% 

TRANSYLVANIA 25,520 1,189 4.66% 

TYRRELL 3,856 1,543 40.02% 

UNION 84,211 13,427 15.94% 

VANCE 38,892 17,512 45.03% 

Wake 390,787 81,086 20.75% 

Wake 32,593 6,971 21.39% 

WARREN 17,265 9,847 57.03% 

Washington 6,173 3,663 59.34% 

Washington 7,824 2,703 34.55% 

WATAUGA 36,952 768 2.08% 

WAYNE 104,666 33,793 32.29% 

WILKES 59,393 2,824 4.75% 

Wilson 43,293 21,695 50.11% 

Wilson 22,768 3,201 14.06% 

YADKIN 30,488 1,295 4.25% 

YANCEY 15,419 151 0.98% 

6,628,637 

County names in bold type indicate the county is divided. 

Page 3 of 3 January 1997  



  

  

  

  

  

  

  League of A‘om an voters of North Carolina 
October:198 1 Proposed Redintricting Pan 

  

  

  

 



  

LWVNC-1997 

District 
-
—
 
w
e
b
 
a
h
 

S
o
o
0
w
o
N
o
a
h
O
N
=
 

Total 

popu- 

lation 

552,386 
552,389 
552,384 
552,383 
552,386 
552,392 
552,387 
552,386 
552,383 
552,387 
552,385 
552,389 
6628637 

EE January 1997 

Comparison Statistics for LWVNC 1991 Plan 

Percent Minority Percent District Varia- 

tion variation 

from from 

desired 552386 

number 

0 0.000% 

3 0.001% 

-2 0.000% 

-3 -0.001% 

0 0.000% 

6 0.001% 

1 0.000% 

0 0.000% 

-3 -0.001% 

1 0.000% 

-1 0.000% 

3 0.001% 

Notes to the comparison statistics: 

Popu- 

lation 

246,380 
145,471 
123,657 
149,412 
118,500 
147,558 
185,027 
136,840 
96,381 
53,489 
56,600 
29,276 

Peri- 

Minority Size (sq. meter 

Popu- 

lation 

44.60% 
26.33% 
22.39% 
27.05% 
21.45% 
26.71% 
33.50% 
24.77% 
17.45% 
9.68% 

10.25% 
5.30% 

mi.) 

6,823 
10,330 
4,564 
2,301 
3,428 
2,273 
6,488 

776 
2,034 
3.817 
3,534 
6,553 

561.8 
722.5 
341.5 
248.3 
330.7 
370.2 
524.7 
128.6 
298.9 
409.1 
472.7 
418.3 

Popu- 

lation 

density 

80.96 
53.47 

121.03 
240.06 
161.14 
243.02 
85.14 

712.30 
271.57 
144.72 
156.31 
84.30 

1 The deviations from the desired number of 552,386 are quite small. All deviations in this plan are 

less than one-tenth of one percent, well within the permissible range. 

2. District size in square miles is derived from the region sizes by the mapping software. They are 

based on polygons that had to be drawn by hand due to lack of any closed figures in the map, and 

should be considered only approximations. The same approximation problem occurs with the 

perimeters; they are useful for comparison purposes, but not definitive. 

3. The population density was calculated primarily to show the extreme variations of density among 

different regions. The coastal plain, full of bays and estuaries and wetlands, is the most sparsely 

settled. Mountain areas have similar characteristics for different geographic reasons. 

 



     

  

L 

! LWVNC. Proposed Alternative ~ 
congressional: Plan, Revision x, Ly / 22 

oa + 

  

  

  

District  Cowity Population White Black esr Black 

a 015 Bertie County : 20388 7790 12531 61.46 
065 Edgecombe County . 56558 24665 31661 55.98 
073 Gates County 9305. 5101 - 4180 44.92 
077 Granville County 38345 23069 14909 38.88 
079 Greene County 15384 8747 6521 42.39 
083 Halifax County 55516 26009 27586 49.69 . 

091 Hertford County 22523 9214 12970 57.59 | 
117 Martin County 25078 13788 11186 44.60 | 
127 Nash County (01) © 58685 39235 18943 32,28 | 
131 Northampton County 20798 8397 12328 59.27 
139 Pasquotank County 31298 19403 11583 37. 01] 
143 Perquimans County : 10447 6979 3426 32.79 | 
147 Pitt County (01) 74586 45507 28057 37. 62 
181 Vance County 38892 21146 17512 45.03 | 
185 Warren County 17265 6593 9847 57.03 | 
195 Wilson County (01) 57318 33767 23140 40.37 | 

Subtotal: DISTRICT = 01, 16 records. 552,386 299,410 246,380 44.60% 

District County Population ~~ White Black Percent Black 

02 013 Beaufort County 42283 28949 13194 31.20 

029 Camden County 5904 4388 1481 25.08 

031 Carteret County 52556 47445 _. 4385 8.34 
041 Chowan County 13506 8349 © 5087 37.66 
049 Craven County 81613 58660 21116 25.87 
053 Currituck County 13736 12051 1545 11.25 
055 Dare County 22746 21766 811 3.97 

095 Hyde County 5411 3596 1781 32.91 
103 Jones County 9414 5687 - 3677 39.06 
107 Lenoir County 57274 34322 22539 39.35 
133 Onslow County (02) 80717 58850 17338 21.48. 
137 Pamlico County 11372 8362 2951 25.95 

147 Pitt County (02) 33338 25136 7864 23.59 
177 Tyrrell County ©3856 © 2297 1543 40.02 
187 Washington County 13997 7556 6366 45.48 
191 Wayne County . . 104666 69172 33793 32.29! 

Subtotal: DISTRICT = 02, 16 record 552,389 396,586 145,471 26.38% 

District County =—===-- population ~ White --—-Black Percent Black = 

03 051 Cumberland CoE] -197158 138778 45663 23.14 %% 
061 Duplin County 39995 25927 13259 33.15. 
085 Harnett County 67822 51117 15315 22.58 
101 Johnston County (03) 10416 8611 ~- 1635 15.70 

129 New Hanover County (03) 91876 83733 "7071 16.13 *% 
133 Onslow County (03) 69121 53089 12540 18.14 

 



    

  

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LWVNC Proposed Alternative Plan, Rev. 1 

Ee 

  
  

  

  

  

January 1992 - Page 2 

141 Pender County 28855. 19828 8770 30.39 

163 Sampson County 47297 30273 15686 33.16 

Subtotal: DISTRICT = 03, 3 recor. 52,384 410,753 123,657 2. 72% ue 

District County or Population white Back Percent Black 

04 069 Franklin County T3644 23288 12843 35.2] 
101 Johnston County (04)%+ 70890 57162 12754 17.99 

127 Nash County (04) 17992 12639 5199 28.90 
183 Wake County (04) 418344 319183 87193 20.84 

195 Wilson County (04) 8743 6856 1756 20.08 

Subtotal: DISTRICT = O04, 5 records. 552,383 419,128 119,745 21.67% > 
| | 

District County Population ~~ White = Black Percent Black 

05 001 Manance County (05) 81645 62315 ~~ 19330 23.68 

033 Caswell County 20693 12155 8436 40.77 

037 Chatham County .. 38759 29423 8845 22.82 

063 Durham County 181835 109886 67654 37.21 

105 Lee County 41374 31216 9401 22.72 

125 Hoore County 59013 47464 10882 18,44 

135 Orange County 93851 75871 14893 15.87 
145 Person County 30180 20740 9106 30.17 

183 Wake County (05) 5036 4227 865 17.18 

Subtotal: DISTRICE = 05, 9 records. 552,386 = 393,207 149,412 27,058 

District County Population White Black Percent Black 
06 001 Alamance County (06) 26568 24445 2164 8.15 

081 Guilford County 347420 249584 91655 26.38 

151 Randolph County (06) 63930 57341 © 5350 3.37 
157 Rockingham County 86064 67893 17548 20.39 

169 Stokes County (06) 28410 26855 1783 6.28 

Subtotal: DISTRICT = 06, 5 records. 552,392 426,618 118,500 21.45% 

District County Population =~ White Black: Percent Black 

07 007 Anson County 23474 12264 11106 47.31 

017 Bladen County 28663 16926 11199 39.07 

019 Brunswick County 50985 41336 9211 18.07 

047 Columbus County 49587 32897 15181 30.61 

051 Cumberland County (07) 77603 31292 41833 54.04 #4 

093 Hoke County il a 22856 9635 9878 43.22 
123 Nontqomery County (07) 21097 14650 5885 27.89 
.129 New Hanover County (07) 28564 11200 17144 60,09 &# 

153 Richuond County A518 30816 12869 28.91 . .° 
FE ——— 105179 37986 26185 24.90 155 Robeson County 

  

t+ changed from initial LAVEC proposal of 10/15/91 

| 
i 

 



    

12176 36.07 

12423 19.32 

| 
552,387 311,530 185,027 33.49% ** 

Non-white population 43.60% | 
: 

LWVNC Proposed Alternative Plan, Rev. 1 
January 1992 Page 3 

- 33754 
64311 

165 Scotland County 
179 Union County (07) 

19025 
51316 

_ Subtotal: DISTRICT = 07, 12’ records. 

  

  

  

  

District County Population White Black Percent Black 
08 025 Cabarrus County (08) 23048 23390 1429 6.20) 

119 Hecklenburg County 511433 364651 134468 26:23 
179 Union County (08) 17909 16788 943 5.27 

Subtotal: DISTRICT = 08, 3 records. 552,386 404,829 136,840 24,778 

District County Population White Black Percent Black 

09 025 Cabarrus County (09) 75891 63896 11424 15.05. 
057 Davidson County (09) . 102034 89544 _ 11592 11.36 
067 Forsyth County 265878 196918 66102 24.86 
123 Nontgomery County. (09) 2249 2120 116 5.16 
151 Randolph County (09) 42616 41209 1017 2.39 

159 Rowan County (09) 11950 11718 158 1.32 

167 Stanly County 51765 45269 5972 11.54 

Subtotal: DISTRICT = 09, 7 records. 562,383 450,674 96,381 17.45% 

District County Population =~ White Black Percent Black 

10 003 Alexander County 27544 25667 1673 6.07. 

005 Alleghany County 9590 9338 177 1.85 
027 Caldwell County 70709 66506 3881 5.49 
035 Catawba County (10) 71677 64882 5851 8.16 
057 Davidson County (10) 24643 23752 722 52.93 
059 Davie County 27859 25194 2482 8.91 
097 Iredell County : 92931 77207 14869 16.00 
159 Rowan County (10)  .—.... 98655 80133 17615 17.86 
169 Stokes County (10) 8813 ' 8473 286 3.25. 

171 Surry County 61704 58383 2780 4.51 
193 Wilkes County (10) 27774 25696 1858 6.69 
197 Yadkin County 30488 28884 1205 4.25 

Subtotal: DISTRICT = 10, 12 records. 552,387 494,115" 53,489 9.68% 

District County Population ~~ White Black Percent Black 

11 009 Ashe County 22209 21960 144 0.65 
011 Avery County 14867 14596 158 1.06 
023 Burke County : 75744 69521 5178 6.84 
035 Catawba County (11) - 46735 41488 4838 10.35) 
045 Cleveland County 34714 66362 17741 20.94 
071 Gaston County 175093 150868 22676 12.95 
109 Lincoln County 50319 45710 © 4108 8.16 
121 Mitchell County (11) 14133 14054 23 0.16, 

 



LHVNC Proposed Alternative Plan, Rev. 1 
January 1992 Page 4 EE 

© 189 Watauga Comty  . .. 36952 35930 768 2. 
193 Wilkes County (11) © . L619 35M 966 .3.06   Subtotal: DISTRICE = 11, 10 records. 552,385 491,000 56,600 10.23% 

~ District County m= Population- White - - Black Percent Black. .: . 

12 021 Buncombe County. 174821 158979 14336 8.20) 
039 Cherokee County = 0170 19313 361 1.79) 
043 Clay County 7155 7061 41 0.57) 

. 075 Graham County 7196 673% L.o.0n 
087 Haywood County 46942 46011. 648 1.38 

089 Henderson County 69285 66158 2361 3.41 
1099 Jackson County 26846 23609 425 1.58 
111 McDowell County 35681 33901 1479 4.15, 
113 Kacon County 23499 22919 385 1.64] 
115 Kadison County 16953 16744 136 0.80) 
121 Nitchell County (12) 300 300 0 0.00, 
149 Polk County 14416 13276 1053 7.30 
161 Rutherford County = 56918 50133 6514 11.44 
173 Swain County 11268 7950 - 19% 1.74 
175 Transylvania County 25520 24121 1189 4.66) 
199 Yancey County 15419 15221 151 0.98 

  

Subtotal: DISTRICT = 12, 16 records. 552,389 512,427 29,276 5.30 
Ng 

North Carolina Totals: 6,628,637 5,010,789 1,456,948 21.98% 

   



" » 
LWVNC Position on Redistricting 

Adopted by the state board March 4, 1994, 

based on concurrence of local Leagues 

  

The League of Women Voters of North Carolina believes that: 

Congressional districts, both houses of the state legislature, and county and municipal government districts 

including boards of education should be apportioned primarily on population. Districts should be single- 

member*, compact, convenient, contiguous and reflect a community of interest. Specific standards for fair 

representation as required by the Voting Rights Act should be assured. 

The responsibility for redistricting and reapportioning should rest with an independent agency 

commissioned by the legislature once every ten years; the agency plan (for redistricting) should be submitted 

for legislative approval without amendment. The independent agency should not be a court. The agency 

should reflect the geographic, racial, and gender make-up of the state population, but no elected official 

should be a member. As a creature of the legislature, the agency would be subject to the Open Meetings law. 

Definite provisions should be made for compensation and staff services of the independent agency. 

A process should be provided to effect automatic, compulsory, periodic redistricting and reapportioning. 

Measures to enact this process should include authority, enforcement powers, time schedule and funding. 

The specific measure may take the form of a constitutional amendment or legislation. 

Specific provisions should be made for court review of redistricting and reapportioning measures and for 

courts to require the independent agency to act on a specific schedule. The state and its political 

subdivisions should be redistricted and reapportioned every ten years within a year of certification of the 

census. Definite time limits should be set for an agency to act after the decennial census figures are 

available in order to comply with federal Voting Rights legislation.. Time limits should be set for initiating 

court action for review of constitutionality of measures. 

  

* Required by current federal law for Congressional districts 

 



  

i, : |} 

Board of Directors 
President 

Marian Dodd 

Raleigh 

First Vice President 

Katherine Colwell 

Pinehurst 

Second Vice President 

Jane Warsaw 

North Topsail Beach 

Secretary 

Pauline Joos 

Jacksonville 

Treasurer 

Jana Albritton 

Wilmington 

Directors 

Sherry Kelly 
Greensboro 

Beth Lazer 

Asheville 

Judith McLeod 

Marshall 

Maethel Shindelman 

Franklin 

Kathryne Thompson 
Nags Head 

SandraTrivett 

Asheville 

Office 

League of Women Voters of orth Carolina 

May 21, 1998 

Mr. David Daniel 

Clerk of Court 

U. S. District Court 

Box 25670 

Raleigh, North Carolina 27611 

Subject: Alternative proposal for Congressional Districts in North 
Carolina. 

Dear Mr. Daniel: 

The League of Women Voters of North Carolina proposes 
an alternative proposal to the Congressional Redistricting plan adopted 
by the General Assembly of North Carolina. 

As you can see from the 1991 plan is less convoluted than later 
ones which considered racial minority voters more, and earlier maps are 
better in some respects because they divide fewer counties. 

Other considerations ensure adequate representation for special 
coastal interest--marine fisheries, beach protection and tourism, state's 
military establishments, multiple districts representing mountainous part 
of the state, and several fairly compact more-or-less urban districts. 

In designing the maps no partisan political information, voting 
registration, incumbent congressional representation was used. Since there 
is not a requirement in the Federal or State Constitution for residency in 
the congressional district one represents, there is nothing in this plan to 
preclude the present incumbents running in a different district. 

In regard to the past history for redistricting plans, it indicates 
the need to reexamine a new approach in designing districts. Through 
research, the league reached a consensus in 1994, that redistricting and 
reapportioning should rest with an Independent Commission for adoption 

ject m embers. 
League of Women Voters of NE rejection, without an amend ent, by General Asserbly m 

3900 Barrett Dr Ste 311 
Raleigh, NC 27609-6614 
Phone and Fax 

919-783-5995 

1-800-851-VOTE 

In 1991-1992 plans were submitted to the Department of Justice 
and the General Assembly. In 1997 a plan was submitted to a sponsored 

 



  

os 4 
group for a redistricting contest and to the General Assembly. In 1998, an 
alternate proposal was submitted to the chairs of the Redistricting 
Committee of the General Assembly and a presentation was made during 
a public hearing for congressional redistricting. 

In the event, the General Assembly plan is rejected by the court, 

the League of Women Voters submits an alternative plan to the court for 
Congressional redistricting, and a copy was submitted to the plaintiff. 

Sincerely, he J 

gn aan. Bel 
” Marian Dodd, State President 
League of Women Voters NC 

CC: Judge Robinson Everett 
Diane Henderson, 919.261.7437