Joint Appendix Exhibits Volume I

    No. 83-1968 

IN THE 

l'uprem.r <!tnurt nf tq.r lltnit.rb !;tat.r.a 
OcTOBER TERM, 1985 

LACY H. 'THORNBURG, et al., 
Appellants, 

v. 
RALPH GINGLES, et al., 

Appellees. 

On Appeal from the United States District Court 
for the Eastern District of North Carolina 

JOINT APPENDIX EXHIBITS 

VOLUME I 

JULIUS CHAMBERS 

Emc ScHNAPPER 

C. LANI GurNIER 

NAACP LEGAL DEFENSE AND 

EDuCATIONAL FuND INc. 

16th Floor, 99 Hudson Street 
New York, New York 10013 
(212) 219-1900 

LESLIE J. WINNER 

FERGUSON, WATT, WALLAS, 

&ADKINS, P.A. 

JERRIS LEONARD 

KATHLEEN HEENAN McGuAN' 

LEONARD & McGuAN, P.C. 

900 17th Street, N.W. 
Suite 1020 
Washington, D.C. 20006 
(202) 872-1095 

Counsel for Appellants 

951 S. Independence Blvd. 
Charlotte, North Carolina 28202 
(704) 375-8461 

Counsel for Appellees, Ralph Gingles, et al. 

JURISDICTIONAL STATEMENT FILED JUNE 2, 1984 

PROBABLE JURISDICTION NOTED APRIL 29, 1985 





Ex-1 

PUGH/EAGLIN PLAINTIFFS' EXHIBIT NO. 4 

Table 1-A 
Comparison of Black Population and Black 

Representation in the North Carolina Legislature 
1940-1982 

Population NC Senate NC House 
#of Total Popu- % #of % 

Year Blacks lation Black Blacks Black 

1940 981,298 3,571,623 28 0 0 
1942 0 0 
1944 0 0 
1946 0 0 
1948 0 0 

1950 1,078,808 4,061,929 27 0 0 
1952 0 0 
1954 0 0 
1956 0 0 
1958 0 0 

1960 1, 156,870 4,556,155 25 0 0 
1962 0 0 
1964 0 0 
HJ66 0 0 
1968 0 0 

1970 1.126,478 5.082,059 2'-' ,, 0 0 
1972 0 0 
1974 2 4 
1976 2 4 
1978 1 2 

1980 1,316.050 5,874,429 22 1 2 
1982 1 2 

Sou r l'e:->: Thad Eut·e . .Vul'f/1 ('amliuu IA'.IJi.-./ofil'l' !Jin•dor I!JXl- 1 !1:->~. l!IX::-tHX4 
Thad Eun•. X(Jrfh ('11mliuo .lfrlllll(/1. l{ak·i1-!h: Publi<:ation:-; Divi:-<ion. l!l<IJ - 1!17H 

U.S. Bureau of Censu:-:. 1~1.10. I!Jt,o, i!JiiO, 1970. 19KO 

#of % 
Blacks Black 

0 0 
0 0 
0 0 
0 0 
0 0 

0 0 
0 0 
0 0 
0 0 
0 0 

0 0 
0 0 
0 0 
0 0 
1 .8 

2 Ui 
•) ,, 2.5 
4 •) •_) 

~.u 

4 •) • ) 
•).0 

3 2.5 

•) 
<> 2.5 

11* 9. 1 

':'Six of these m .. ·t·e elcf.:U_·d from majority black distritt:-: that the (;('Jll' t'ai A:-:sL·rnbl ,v was furn:d to dra\\' hy tlw· 

Federal Courts. 



PLAINTIFF'S EXHIBIT 
11 App 3 Gingles 

Appendix 3: "Effects of Multimember House and State Senate Districts 
in Eight North Carolina Counties, 1978-1982" 

CONDENSED SUMMARY TABLE 1 

KEY (X,Y,Z,QJ 
X = number of black 

candidates 
Y = total number of candidates 

(including blacks) 
Z = number of winning 

candidates 
Q = numbet· of winning black 

candidates 

Level of While Voter Support for Black Candidates vs. Black Voter Support liH' Black Candidates in E ight North Carolina Countie:;, House and Senate 
· Primm·y and General E lections in which there wm< at lea:;t one Black Can~lidate, 1 97~ 1!)82"' 

Proport ion of Proportion of Proportion of Proportion of 
white voters black voter:; white voters black voters 
liH' black for black for black f(n· black 

ni<,'NF:HA/, candidate(:;) candidate(s) / ' H. /MARY candidate(,;) candidate(s) 

(5 ) Mecklenburg & Cabarrus 

(1, ti, 4, I ) 1!178 Senalt• .41 .!l4 (1, 5 , 4, I) Hl78 Senate .47 .87 
(1, 5, 4, 0) 1980 Senate .23 .78 

(1 , 7, 4, ()) 1!182 Senate •l•l 
. ~),) .!14 (1, G, 4, 1) HIH2 Senate .J~ .8;3 

Wl Meck lenburg 
(1 , li, 4, ]) l!J78 SenalP .40 .!J4 (l, 5, 4. 1) I!l78 Senate .50 .87 

(l, 5, 4. 0) WHO Senate .25 .79 
(1 , Hi , H, 0) l!J8() HousP .28 .!J2 (1 , ] ;1, 8, I) l !JSO House .22 .7 1 
(I, 7, 4, ]) l!IH2 Senate .31 .!)4 (1 , ti, 4, 1) Hlt\2 Senate .:1;-~ 8'·' • <.> Polk wins in 
(" IH, i-1 , I) 1!182 House .42 .2!J .!J2 . 88 (2, ll, 8, 2) l !J82 Hom;e .50 .:JH .79 .7 1 HJ82 Meek. Sen . 

gener. 
Alexander loses 

(5) Cabai'I'US in l!J78 Cabarrus 
0 . G, 4, I ) l!J78 Senate ,;)::; .!J2 (1 , 5. 4, 0) I !J78 Senate _;-~[) .75 primary. 

(1, 5, 4, U) l!IHO Senate .21 .79 Polk loses in 
(l, 7, I , 0) l!IX2 Senate ,;l7 .!14 (1, (i , 4, () ) 1!182 Senate .ao .7(; I !IH2 Cabarrus 

primary. 

tr_j 
><: 

I 
1:\:) 



TABLE 1 (continued) 

Proportion of Pt·op(lttion of Propor t ion of Pmportion of 
white voter:-; black voter~ white voter~ black voter" 
Jill" black for black fill" b lack fin· black 

(,'J;'N8UA/, candiclate(s) cancliclate(s) ! ' HI MARY cand idate(s) candidate(s) 

(li) Durham 
(1, .J, ~. 0) I !17H Senate• . 17 .05 .ll!J .92 

(ih ·p. Bl X 

(I ' ::, ;{ , I) I!J7~ House .48 .7!1 (2, 7, ;), I ) 1978 House .10 .Hi .32 .iJO 
(1 , ;{, ;), I ) 1 !1~0 Hotbe .-1!1 .!10 No P rimary Hli>O House X 

(I ' 4, ;{, ] ) 1!1~2 House . .J:~ J:i!l (2, 4, 3, I ) H)ti~ House .26 .:37 

{7) ]•(JI"sy th 

(2, !l, " · 0) l !PX House .:12 . )• ~ .. ) . ) .H5 .2!i (" "· 10, 5, I ) l!J7H House .21> .013 .17 .7(i .2!) .5:{ 
(I Rep Bl .:{l .HG (1, 3, 2, 0) l!lXO Senate . 12 .!i l 

( I , 10, 5, 0 ) I!IHO Hou:-;c· .42 .41i .H7 .!)4 (2, 7, !i, I ) l !IXO House .40 .Ill .l:iG ,;{() 

(:!, X, ;,, 2) !!IX~ House (2, 11 , 5, 2) 1!182 House .2!i ,;{() JJO .9 1 t_:rj 
(5) Wake :>< 
(1, li , 1 ;-~. I ) l!IHO Hou"e .H .!10 (l , 1 ~. li, 0) l!17H House .21 .7(i I 

( I, 17, li , I) I!IX2 House .45 .!ll (1, 9, !i, I) J!IHO House .31 .H I 
~:,<;) 

(1 , 15, G, I) 19H2 House .il!l .t->2 

(;{) E-W-N 
1!11)2 House (], 7, 4 , 0) .04 _(j(j 

1!182 1st Cong 
Primary (], 3, 2, I) .02 .t->4 

I !182 2nd Cong 
Primary (], 2, I , 0) .05 .!II 

([,) Michaux wins in 
Eclg<!combe 

1!1132 House (1, 7, 4, 0) .02 . m~ Edgecombe 
1!182 I st Cong-

Primary (I ' ;-), 2, I ) .02 .t->4 
I !IH2 2nd Cong 

Primat ·y (I ' 2, I , 0 ) .oa .!17 
1!1:->2 Cou nty l!lH2 County 0 0 .04 .02 

(2, 4, ::, 2) Commi~:-;i 01wr .:·~X .:·Hi .!Jl .!14 C<,mmi:-;::-; ioner (4, 10, :1 , 2) . 14 .27 .75 .82 



(~ ) Wibon 

(5J N'"h 

Proportion of 
white vote r ti 
for black 
candidate ( ~ ) 

TABLE 1 (continued) 

Proportion of 
black voter~ 
fi>r black 
ca nd idate(") 

I!Jtl2 Hou~e 
HJH2 L; t Con!( 

I,rimary 
1 !JH2 2nd Con!( 

Primary 
1 !J7G County 
Commi~.s ioner 

I!J71i House 
1 !JH2 1st Con!( 

Primary 
HJH2 2nd Cong 

I)r imary 
l!Jtl2 County 
Commi~sione 1· 

I'NIMANI' 

(1 , 7, 4 , 0) 

(1, ::l, 2, 0 ) 

(1, 2, 1, 0 ) 

(1 , 1, 7,0) 

(1, 7, 4 , () ) 

(1 , ;J, 2, 1) 

(1, 2, I , 0) 

o. G, a. oJ 

Proportion of 
white vote rs 
for black 
candidate(" ) 

.02 

.OG 

.07 

.32 

.02 

.Oii 

.Uti 

.OH 

Propm·tion of 
black voter s 
for black 
cand idate(" ) 

.7G 

.Hii 

. H~ 

.77 

.5H 

.73 

.81 

.~2 

'1' l n Etlg·l'ct, lll iH·. Wilstlll aw l Nc1s h tlll ·n · \\'as tllll.v black l'CI IHiitla te li11· House m· Senat<· in t ht' J)t.' riocl I ~J7K- 1!1Xi. Data liu- t hose <:<Hintit·s al't• l>ase<l in ad< I ilion on a IH7H l :ounly Commission race in 
Wi\:-:11 11 , I!JX~ ( 'on,l!JVS:-> ional l 'r imari<'s , anti Etl g'l.~tomht• anti Nash IHH~ County Cunm1ission Prim;wi{'s and ( ;cnc ral Ekdi<m:->. 

N = f);: 

r\du;~ l tlis trid ran•s - ::0 ll oust• & St•uat t• 0 '&(;) 
.J ( 'ount y ( 'ommissiont·r (P& ( ;) 

~ ( 'oll.l! l 'rim;u·i(•:-; 
:lli 

t::r1 
>:: 

I 
~ 



CONDENSED SUMMARY TABLE 2 
Ranking of White Voter Support for Black Candidates vs. Black Voter Support for Black Candidates in Eight North Carolina Counties, 

House and Senate Primary and General Elections in which there was at least one Black Candidate, 1978-1982.* 

Rankin~ of white Ranking of black Ranking of white Ranking of black 
vote r >< for b lack voters lin· black vote rs for black voters lin· black 

GENb'NA I, cand idate(s) eand idate(s ) I'NIMANl" candidate(s) candidate(s) 

(G) Mecklenbu1·g- & Cabarru ,; 

(I , G. ~ . 1) 1H7X Senate (1, 5, 4, I ) 1!J7H Senate las t 
(1, 5, 4, (}) l! lXO Senate las t 

(1 , 7, 4, 0) 1 !lH2 Senat e li (I ' 6, 4, I ) 1!lH2 Senate 5 

(!)) Mecklenburg-

(1 . li , ~ . I ) 1H7X Senat e (1, 5, 4, I ) l!l7X Senate last 
(1 , 5, 4, 0) l!lHO Senate last 

0 , Iii, X, 0) WHO House last (1, t ;·~. H, 1) l!lHO Hull>< <! 10 
(1, 7, ~ . 0) 1HH2 Senate li (I ' li , 4, 1) 1!lH2 Senate :; 
(2. IH, X, 1) I!IX2 Hou<e 7 14 2 (2, 9, 13, 2) 1!lH2 House 7 last 2 Alexander loses 

in I!J713 Caban·us 
(!i) Cabar rus 

(1 ' li , ~ - 1) 1!17H Senate 5 n. 5, 4 , ol HJ7H Senate last primary. 
(1 , 5, ~. 0 ) l!lXO Senate last Polk loses in 

0. 7, 4, ()) I !IS2 Senate (i (1 , li, 4, 0) I!JH2 Senate 5 1!J82 Cabarrus 
primary. 

(li ) Durham 
(1, 4, 2, 0 ) I !17S Senal<· la,;t ., ,, 

(l{ep B) 

(I' :I , ;-:, I) 1!!7H House la,;L (2, 7, :~. I) 1!!7S House last (i 2 
(1 , ;:, ;{, I ) l!JHO House last No Pl"imary l!lt\0 House X X 

(I ' 4, ;{, I) I!IH2 House "·' " 12, 4, a, I ) HJH2 Hou><e nex t lo last las t 2 

17) 1·< ..-s_v th 

(2. !J, ' '· 0 ) I!J7S House last next to las t li (:1, 10, G, I ) I!J7H House 7 last K ·• ,., 2 
(I lte p BJ 11. cl, 2, Ol I!IHO Senate la,;t 

0. 10, "· 0) l!JHO House last (2, 7, "· I ) I!JHO House next lo last Ia,;( 2 
(2, X, G, 2) l!JS2 House Ia ,;( next to la,;t 2 (2, I I. !l. 2) I!JH2 House H 4 2 

M 
~ 
I 

c.n 



TABLE 2 (continued) 
Ranking of white Ranking of black Ranking of white Ranking of black 

voters for black voters for black voters for black voters fur black 

Gt'NERAL candidate(s) canclidate(s) PRIMARY candidate(s) canclidate(s) 

(5) Wake 
(1, 13, (i , I) (i (!, 12, 6, 0) 1!)78 House 9 
(1, 17, 6, I) 3 (I , 9, li, I ) HJ80 House 8 

(1, 15, 6, I) 1982 House 5 

(;~) E-W-N 
HJ82 House (! , 7, 4, 0) last 
1982 1s t Cong 

Primary (! , 3, 2, I) last 
1982 2nd Cong 

Primary (! , 2, I, 0) last t;rj 
Michaux wins in :>< 

(5) Edgecombe Edgecombe on ly I 
0':> 

1982 House (! , 7, 4, 0) last 
lfJ82 1st Cong 

Primary (! , 3, 2, I) last 
HJ82 2nd Cong 

Primary (I , 2, I, I) last 
(2 , 4, 3, 2) HJ82 County 2 3 2 1982 County (4, 10, 3, 2) last t ied fin· last 4 3 2 I 

Commi::;sione1· Commi~sione 1 · 

(4) Wilson 
1982 House (! , 7, 4, 0) last 
1982 1st Cong 

Primary (!, 3, 2, 0) last 
1982 2nd Cong 

Prima1·y (!, 2, I, 0) last 
J!J7(i County 

Commissionet· (I ' J :~. 7, 0) II 



(4) Nash 

GENENAL 

Ranking of white 
voter~ for black 
candidate(s) 

TABLE 2 (continued) 
Ranking of black 
voters for black 
candidate(s) 

1976 House 
1982 1st Cong 

Primary 
1932 2nd Cong 

Pt·imm·y 
HJ82 County 

Commissioner 

PRIMARY 

(1, 7, 4, 0) 

(1, 3, 2, l) 

(1 , 2, l , 0) 

(l , 6, 3, ()) 

Ranking of white Ranking of black 
voters f(lr black voters for black 
candidate(s) candidate(s) 

7 

tied for last 

last 

6 

1' l n l~;dg-e<:ombe, Wil~on and Nash there was unly black tanditlate for House or Senate in the period 1H7X-HIH2. Data liw lho~c co untie:-; a l'c based in a(ltlition on a HJ7ti County Commi:>sion race in 
Wilson, HJH2 Cong-ressional Primaries, and Edgel'otnbe and Nash IH02 County Commis::;ion Primarie~ and General Elections. 

N = 5:1 
Actual district races = :10 House & Senate (P&G) 

4 Cou nty Commissioner (P&G) 
~ Cong Primaries 
:lli 



CONDENSED SUMMARY TABLE 3 
Level of White Voter Support for Black Candidates vs. Black Voter Support for Black Candidates in Eight North Carolina Counties, 
House and Senate Primary and General Elections in which there was at least one Black Candidate, 1978-1982. * 

Pmportion of Pmportion of Proportion of Proportion of 
the votes cast t he votes cast the votes cast the votes cast 
by whi te by black by white by black 
voters which voters which voters which votet·s which 
go to t he black go to t he black go to the black go to the black 
cand idate(s) candidate(s) candidate(s) candidate(s) 

GENERAL PRI MARY 

P'wn P',w P'wu P'nn P'un 

(5) Mecklenburg & Cabarrus 
(1, 6, 4, I ) I !!78 Senate . IH .38 (1, 5, 4, 1) 1978 Senate .16 .53 

(1, 5, 4, 0) 1 !!80 Senate .09 .52 
(1 , 7, 4, 0) I !!82 Senate .11 .46 (1 , G, 4, I) 191:12 Senate .12 .49 

(!)) Mecklenbut·g 
(1, 6, 4, I) l!l78 Senate .15 .38 (1, 5, 4, I) 1978 Senate .17 .55 Alexander 

(1, 5, 4, 0) 1980 Senate .O!l .53 loses in 1 !l78 
(I, W, 8, 0) J!JHO House .05 2'' • o) (1 , 13, 8, I) 1980 House .04 .34 Cabanus 
(1, 7, 4, I) I !lH2 Senate .11 . 47 (I, G, 4, I) 1982 Senate . I I .53 primary . 
(2, 18, 8, I) 1!!82 House .12 .48 (2, !l, 8, 2) 1982 House .17 .54 
(f>) Cabarrus 
(1, G, 4, I ) I !!78 Senate .14 .31 (1, 5, 4, OJ HJ78 Senate .15 . :~7 Polk loses in 

(1 , 5, 4, 0) 1980 Senate .0!) .:w 1982 Caban·us 
(1, 7, 4, 0) J!lti2 Senate .13 .27 (1, H, 4, 0) 1!!82 Senate .Hi .38 primary 

((l) Durham 
(1, 4, 2, 0) W78 Senate .12 .03 

(Rep. B) 
(1, 3, ;~, I) 1978 House .28 .36 (2, 7, 3, I ) l!l78 House .10 .9!! 
(I, ;~, 3, I) 1!!80 House .32 .35 No Primary 1980 House X X 

(1 , 4, 3, I) 1!!82 House .2G .78 (2, 4, ;~ . I) 1982 House .35 .91 

(7) ~(u·syth 
(2, 9, 5, U) l!l7b House .w .M (3, 10, 5, I) HJ78 House . 14 .(i3 

(I Rep B) (1, ;J, 2, 0) 1!!80 Senate .07 .51 
(1, 10, 5, 0) 1!!80 House .07 .24 (2, 7, 5, I) 1!!80 House .15 .55 
(2, IJ, 5, 2) 1!!82 Ho use .21 .55 (2, 11, 5, 2) 1!!82 House .15 .55 

M 
~ 
I 

00 



TABLE 3 (continued) 

Propor tion of Proportion of Proportion of Pmportion of 
the votes cast the votes cast t he votes cast the votes cast 
by white by black by white by black 
voters which vote1·s which voters which voters which 
go to the black go to the black go to the black go to the black 
candidate(s) candidate(s) candidate(s) candidate(s) 

GENERAL PRIMARY 

P'wu P',w P'wu P',:n P'un 

(5) Wake 
0, J;{, G. I) Hl80 House .Ofl . HJ (1, 12, G, 0) IH78 House .05 .40 
(1, 17, G, I) 1982 House .09 .18 (1, 9, G, I) 1980 House .09 .50 

(1, 15, G, I) 1982 House .10 .41 

(3) E-W-N 
HJH2 House (1, 7, 4, 0) .01 .3G 

trl 1982 bt Cong 
~ Primary (1, 3, 2, I) .02 .90 I 

Hl82 2nd Cong ~ 

Primary (1, 2, I, 0) .05 .94 

(5) Edgecombe 
HJ82 House (1 , 7, 4, 0) .01 .31 Michaux wins 
J!JH2 1st Cong in Edgecombe 

Primary (1, 3, 2, I) .02 .fl2 only 
1982 2nd Cong 

Primary (1 , 2, 1, 0) .02 .99 
l fJ82 County HJ82 County 

(2, 4, 3, 2) Commissione1· .40 .till Commissione1· (4, 10, ;{, 2) .02 .H7 

(4) Wilson 
J!l82 House (1, 7, 4, 0) .01 .52 
1982 I st Cong 

Primary (1, 3, 2, 0) .07 .98 
l!l82 2nd Cong 

Primary (1, 2, I , 0) .07 .99 
IH7ti County 

Commissioner (1 , 13, 7.0) .05 .:{0 



GENEUA/, 

(5) Nash 

Proportion of 
the votes cast 
by white 
voters which 
go to the black 
candidate(s) 

TABLE 3 (continued) 

Proportion of 
the votes cast 
by black 
voters which 
go to the black 
candidate(s) 

PRIMARY 

J!J7G House (1, 7, 4, 0) 
1982 bt Cong 

Primary (1 , 3, 2, 1) 
1982 2nd Cong 

Primar y (1, 2, I , 0) 
l!JH2 County 

Commissionet· (1, 6, 3, 0) 

Proportion of 
the votes cast 
by white 
voters which 
go to the black 
candidate(s) 

.01 

.07 

.OG 

.04 

Proportion of 
the votes cast 
by black 
voters which 
go to the black 
candidate(s) 

:31 

.79 

.82 

.49 

*In Et l ~ccombc, Wil:-;on and Na:-;h there wa:-; only black cant lidate for House m· Senate in the period IH7H- lHXi. Data fur those counties arc based in achl ition on a 197fi County Commission race in 
Wil:-;on, IBX~ Con!{ress iunal Primari(•s, atHI Edg-ecombe and Nash HJt)~ County Commission Primaries and Gcnct·ctl Elcdions. 

N :::: 5:1 
Actual dis trid races = :~0 Hou:.;c l'\: Senate (I~&G) 

4 County Conuniss ioner (Pl~G) 
_1 Cung- Primat'i(•s 
ati 



PLAINTIFF'S EXHIBIT 11, APP. 6#4 Gingles 

APPENDIX 6 to "Effects Multimember Districts" 
Black Legislative Representation in States with Black Population over 15% 

Predominantly single Predominantly s ingle Predominantly single 
Percent member dis tricts in areas #of Black member districts in areas #of Black member districts in areas #of Black 
population of Black concentration as Reps. in of Black concentration as Reps. i1\ of Black concentration as Reps. in 
Black (1970) of July 1977 July 1977 of July 1982 July 1982 of July 198:3 July 198:3 

Alabama 26.4 YES 15 YES 16 YES 20 
Arkansas 18.6 NO 4 NO 5 NO 5 
Florida 15.5 NO a NO 5 YES 12 
Georgia 25.9 YES 23 YES 22 YES 24 trj 
Louisiana 29.9 YES 10 YES 13 YES 13 >< Maryland 17.9 19 * 21 ** 23 I 

f--6 
Mississippi :36.8 ' NO 4 YES 17 YES 17 f--6 

North Carolina 22.4 NO G NO 4 YES & NO 13 
South Carolina 30.5 YES 13 YES 15 YES 20 
Tennessee Hi.1 YES 11 YES 12 YES 13 
Virginia 18.6 NO 2 NO 5 NO 7 

1977 (omitting Maryland) 1982 (omitting Maryland) 1.9/M (omitting N.C. & Maryland) 
Average # of Black Representatives in States with 
Predominantly Single Member Districts in Black Areas 3.8 (TOTAL = 19, N = 5) 4.8 (TOTAL = 19, N = 4) () (TOTAL = 12, N = 2) 

Average # of Black Representatives in States with 
P1·edominantly Single Member . Districts in Black Areas 14.5 (TOTAL = 72, N = 5) 15.8 (TOTAL = 95, N = 6) 18.4 (TOTAL 129, N 7) 

*;{ member di~tril.:ts used throughout, Bla<:k:-: only clederl from majurity Blacl\ mmds. 
**mix of I, ~. and;{ per:-;on dist1·i t:ts, Blacks only clcd(:d from majority Black mmds and :-~mds, with one exeeplion 



100 
90 
80 
10 
60 
50 
40 
30 

Success in GeneraL Elections 
(<ro of candidates that Los~ by party fry race) 

1970-~ 1982 

B W B 
Democrat6 Republicans 

G-ing~ 
Exhtbi.tJq 

100 
90 
80 
70 

( 60 
50 
40 . 

30 
20 
10 
0 o~o~o N 

W W B 
Democrats Republicans 



Partjcipation in General Elections 
(

0/o of candidates of each party by r~) 

1970-1')82 
'lo 

155 •%..5'1lo 
0 .: •• 

90 .228: 8'1A~o 90 31 =62'7o 

so 80 
70 . 70 
60 tri 

:>< 
I 

50 50 I-" 
CA:l 

40 40 
30 30 
20 20 
10 10 
0 0 o•o'o 

B w B B w B 
Democrats Republicans · Democrats L«publicans 

EXHIBIT 19 
Gingles 



Ex-14 

PLAINTIFF'S EXHIBIT 20 GINGLES 
The Disadvantageous Effects of At-Large Elections 

On the Success of Minority Candidates 
For the Charlotte and Raleigh City Councils 

Bernard Grofman 
Professor of Political Science 
School of Social Sciences 
University of California, Irvine 
Irvine, California 

May 20, 1983 

I. Campaign Expenditures in the District-Based 
and At-Large Component of the Charlotte City Council and 

Raleigh City Council Elections in 1979 and 1981 

We would like to test the hypothesis that at-large elec­
tions are more expensive to run than district-based cam­
paigns. Intuitively it would seem very reasonable that at­
large elections, involving as they do larger constituen­
cies, would be more costly. 1 However, there are a number 
of methodological problems in empirically validating what 
might appear commonsensically obvious; even though the 
few available studies (e.g., Grofman 1982; Jewell1982) all 
support the truth of the proposed hypothesis: 

· (1) There are differences in spending patterns between 
incumbents and non-incumbents. Moreover, those differ­
ences are complicated by the considerable incumbency 
advantage in raising money versus the countervailing 
lesser need of highly visible incumbents to spend money 
to win elections. Also the magnitude of the incumbency 

1 Campaign funds are often spent somewhat differently in at-larg·e 
than in district elections; for the latter, use of city-wide media (e.g., 
radio, TV, city newspapers) is less efficient than for the former and 
this may reduce somewhat the cost advantages produced by the 
smaller scope of district-based campaigns. 



Ex-15 

advantage is often different in at-large than in single 
member district elections. 

(2) Both at-large and district races contain candidates 
who run with little chance of victory (and with minimal 
campaign expenses), but the number of such candidates is 
generally greater in at-large elections. 

(3) Many candidates largely finance city council cam­
paigns through their own funds, and such personal re­
sources vary widely, introducing idiosyncratic features 
which are hard to control for because of the small number 
of mixed system elections for which we have campaign 
funding data available for analysis. 

Nonetheless, each of these methodological problems 
associated with analyzing comparative campaign expen­
ditures across different types of election systems may be 
solved (or at least mitigated) if(1) we distinguish between 
incumbent and non-incumbent expenditures (2) for both 
incumbents and non-incumbents we focus on the expendi­
tures of the winning candidates, and (3), we combine data 
so as to obtain a larger sample size and more reliable data 
estimates. We shall look at Charlotte City Council and 
Raleigh City Council campaign expenditures patterns, 
combining 1979 and 1981 data. 

In Charlotte there were four at-large seats and seven 
district seats in both the 1979 and 1981 elections (see 
Appendices 1 and 2). Combining data for the two elections 
we find winners at large averaged over $12,000 on cam­
paign expenditures (whether they were incumbent or 
non-incumbent); while in the district based elections, win­
ning challengers spent ony $5,815 and winning incum­
bents spent only $3,198 (see Table 1). Thus, campaign 
costs in Charlotte City Council at-large elections were, on 
average, more than twice those for district elections in 
that city. 



Ex-16 

In Raleigh, for both the 1979 and the 1981 election, 
there were two at-large seats and five district seats (see 
Appendices 3 and 4). Combining data for the two elections 
we find incumbent winners at-large spent an average of 
$9, 105 while incumbent district winners spent an average 
of only $5,344; non-incumbent at-large winners spent an 
average $11,925 while non-incumbent district winners 
spent on average only $5,213. Thus, at-large campaign 
costs in Raleigh at-large city council elections were, on 
average, roughly twice those for district elections in that 
city. 

II. Success of Black Candidates in the District-Based 
and At-Large Component of Charlotte City Council 

and Raleigh City Council Elections 

The considerably higher expenditures required to run a 
successful at-large race in Charlotte imposes a burden on 
minority groups (such as blacks) who are economically 
disadvantaged. This financial burden, combined with ra­
cial bloc voting which makes for a greater difficulty of 
black success in at-large race with a primarily white elec­
torate as compared to a district race with a primarily 
Black electorate (e. g., Charlotte Districts 2-3), has meant 
that Blacks are disproportionately excluded from the at­
large council seats in Charlotte. In the period 1977-1981, 
of the 21 district seats contested, Blacks won 6 (28.6%); 
while of the 12 at-large seats contested Blacks won only 2 
(16. 7%), despite the fact that there were more Black 
candidates for the four at-large seats than for the seven 
district seats. In the preceding period, 1945-1975, under 
a pure at-large system, Black representation was even 
less, averaging only 5.4% (Heilig and Mundt 1981; see also 
Heilig, 1978; Mundt 1979). 

As in Charlotte, Black electoral success in Raleigh was 
considerably greater in the district than in the at-large 
component of the city council elections in 1977-1981. Of 



Ex-17 

the 15 district seats contested, Blacks won three (20.0%), 
while of the six at-large seats contested, Blacks won no 
seats (0.0%), despite the fact that there were propor­
tionally about as many Black candidates contesting the at­
large elections as contesting the district elections. This 
finding of greater minority success in a district-based 
system (or the district-based component of a mixed sys­
tem) than under an at-large or multi-member district 
system has been repeated in a large number of munici­
palities and other jurisdictions where there exists a sub­
stantial minority population and patterns of polarized 
voting (see esp. Engstrom and McDonald 1981; Karnig 
and Welch 1978, 1979; Grofman 1981; and overviews of the 
literature in Engstrom and McDonald 1984 forthcoming 
and in Grofman 1982b). 

"Indeed, few generalizations in political science ap­
pear to be as well verified as the proposition th:;~t at­
large elections tend to be discriminatory toward 
black Americans" (Engstrom and McDonald, 1984 
forthcoming). 

III. Summary 

We examined the campaign expenditure patterns for 
the at-large and district components of Charlotte and 
Raleigh, North Carolina city council elections and found 
that successful at-large election campaigns are more ex­
pensive to run than successful district campaigns. We 
then looked at the success of black candidates in recent 
Charlotte and Raleigh city council races and found dra­
matically greater success for black candidates running in 
the district-based elections than for those running for the 
city-wide seats. In reducing their likelihood of obtaining 
office if they do seek it, and/or in increasing the amount of 
money which must be spent to achieve office, at-large 
elections in Charlotte and Raleigh had a discriminatory 
effect on Black candidates, when compared with district 
elections in the same cities. 



1979 
expenditures 

average 

1981 
expenditures 

(N = 2) 

average (N = 2) 

1979 and 
1981 

·combined 

average 
(N = 4) 

Table11 

Campaign Expenses: Charlotte City Council, 1979-1981 
Winning Incumbents~ 

At-large District 

$ 554 
1,684 
1,907 
2,699 
5,784 

$5,706 2,914 
4,945 5,675 

$5,826 $:1,031 

Winning Incumbents 
At-large District 

$18,452 
HJ,6G9 

$19,0G1 (N = 5) 

$3,119 
1,936 
2,777 
4,531 
4,800 

$3,433 

Winning Incumbents 
At-large District 

(N = 2) 

(N = 5) 

average 
(N = 2) 

(N = 5) 

$12,194 (N = 12) $4,198 (N = 9) 

Winning Non-Incumbents 
At-large District 

$18,142 
19,100 

$18,621 

Winning 
At-large 

$7,014 
5,292 

$6,153 

None 

Non-Incumbents 
District 

$8,717 
2,913 

(N = 2) $5,815 

Winning Non-Incumbents 
At-large District 

$12,387 (N = 2) $5,815 

1There were not enough winning Llack candidalt•s to mak{! it J(!asiblc to separately tabulate by race of candidate. The raw data on which this tab le wa:-> based is provided as appcndice.s to this 
re:->carch nntc. 

~In W7~1 and HJHI all incumbent:-: running liw recleclion to the Charlotte City Counily won recledion. In l97~J ~'of 11 iw.:umhents sought reelection; in 19K l , 7 of 11 did. 

trj 
:>< 

I ....... 
00 



1979 
expenditures 

average (N = 1) 

1981 
expenditures 

average (N = 1) 

Hl79 and 
1981 
combined 

average 
(N = 2) 

Table12 

Campaign Expenses: Raleigh City Council , 1979- 1981 
Winning Incumbents 

At-large District 

$3,598 
$3,598 

$15,723 
4,187 

257 
5,048 

$ 6,804 

Winning Incumbents 
At-large District 

$14,611 
$14,611 (N = 4) 

$5,310 
1,301 

$4,383 (N = 1) 

Winning Incumbents 
At-large District 

$9,105 (N = 8) $5,344 (N = 2) 

Winning Non-Incumbents 
At-large District 

$10,016 
$10,016 

~ 
$8,962 

Winning Non-Incumbents 
At-large District 

$13,834 
$13,834 (N = 1) 

$1 ,463 
$1 ,463 

Winning Non-Incumbents 
At-large District 

$11 ,925 (N = 2) $5,213 

1Tiw n.! wen • not c nuug h winning black tandidatc:-: tu make il lt.·as iblc tu separate ly tabulate b~' race of tomdidatc. ThL· raw data un \\'hich this table was based is provided as appe ndices tu this 
rcsean:h IHJ l l' . 



Ex-20 



-.. 

WBITE PEOPLE 

~FO'E IT'~ TOO LATE 

FOUIUI.'Jf NO'r IIJI~ JUIOt'BBB CBJ1J,11t2 

PLAINTIFF'S 
EXHIBIT 

25 
Gingles 

DO YOU WANT? 
Hetroet worko"9 besode you, Y''Y' ..,,fe and daughter\ on your 

molls and foctoroes' · 

Httroet eotong ~sode you on ol~ publoc eotong places' 

Hetroet rodong ~sode you, -,.oLr '''"'(' and your daughters on 
buses. cobs and trotns) 

Hetroe~ slet-pong '" the so~ hct.eh ~ ~eomong kouses' 

Hetroet teochong and dosciplon.rg your choldren on sckool' 

Netroet sottong woth you and your fomoly at all publoc mfttongs) 

HetrMt Goonq '"white sch'ool\ on, I ..,lutl! choldren qJ•na to,N~ro 
\Cho)('lfs) 

HttrMt to <><Cui)\ thl' \Oml' ho\o>otul r.>om\ ..,,,.., you and \'Our 
..,ofe onJ <.luughter~' 

Netroe• O\ \<Jur foremen and O'Wcr\ccr\ on the moll\' 

Httrell ui.lng vnur toolct locoloton' 

Honhern ,.liticel lebot lee4en h••• recently wdere4 thet 
ell 4-rt M ope11e4 t. Hetroet 011 wnio11 ''~rty. This will 
lee4 t. wltit11 e114 Nttroet war\int on4 li•int t.tethtt 111 
the S.Uth •• they 4e In the Nerth. Do you we11t t~etr 

FRANK GRAHAM FAVORS MINGLING OF THE RACES 
HI ADMIT1 THAT HI FAVOU MIXING HIGlOU AND WHITIS- HI SAYS SO IN 

THI li..OlT HI SIGHID. (Fet Preot ef This, Reed P'ete 167, Ci•il llthtt le,..t.) 

DO YOU FAVOR '!'HIS-- WANT SOME MORE OF IT? 
IF YOU DO, VOTE FOR FRANK GRAHAM 

IUT IF YOU DON'T 

VOTE FOR AND HELP ELECT 

WII·'·IS SDifJl'B fo.- SBNA'I'OB 
HE WILL UPHOLD THE-T1l.ADIT10NS OF THE SOUTH 

KNOW THE TRUTH COMMmEE 

Ex-21 



,· 



Number 
of BLack 
Elected 
Officials 

300 

250 

200 

150 

100 

50 

0 ~~----~----------------------------------10 . 71 72 73 74 75 76 71 78 79 80 81 

Years (1970-1981) 

Number of Blacl< Elected Officials 
it1 Nort11- Caroluta(l'JTO,_l98l) 

Ex-22 

Gingles 
ExhLr{t,41 



. I 
I 

I I 

I· 
'l I, 

I 
!.: 
1' 

:I 

I, 
' 

:I 
I 

I 
I 

' I 

I 
I 

! ; 
I 

I: 
I ' 
I i 
I 

I 
i 



Ex-23 

PLAINTIFF'S EXHIBIT 
52 

Gingles 

Vallhtine 
For Congress 

Dear Fellow Democrat: 

Tuesday, July 27th is a very important day for Democrats in -
Durham County. It is a day when you have a chance and 
obligation to influence the direction in which our national 
government will move during the critical years ahead. 

That choice is whether you want to be represented in Congress by 
a big -government, free-spend ing libera l, or whether you want to 
be represented by a person whose thinking is much more in tune 
w ith the ma jority of our people. 

I think the choice is very clear. 

My opponent's liberal record is well -known. 

While serving in the state legislature, among other things, he 
sponsored a bill wh ich would have raised your personal income 
taxes by as much as 40 percent. 

He also sponsored a bill which could have forced you to pay 
dues to a labor union whether you wanted to or not. 

I am opposed to his kind of liberal thinking and I believe the 
majority of the people in our district are too. 



Ex-24 

I want you to know that I am opposed to higher taxes. I plan to 
introduce a constitutional amendment which would requi re a 
balanced federal budget, wh ich would force the government to 
live with in its means. 

That would cause interest rates to come down which would revive 
agriculture, help industry grow and create more jobs for our 
people, thereby bringing down unemployment. 

I have also made a commitment to open a fully-staffed 
Congressional Office in Durham, so that you will never be more 
than a local phone call away from help with your problems with 
the Federal Government. 

I know it's July and it's hot. Many folks are on vacation. Many are 
busy w ith tobacco. It's easy not to stop and take the time to vote, 
but you must. 

Our polls indicate that the same well organized block vote which 
was so obvious and influential on the 1st Primary will turn out 
again on July 27. My opponent will again be bussing his 
supporters to the polling places in record numbers. 

If you and your friends don't vote on July 27 my opponent's block 
vote will decide the election for you . 

A Congressman We Can Be Proud Of 
Paid for by the Tim Valentine for Congress Committee. 

C.T. Lane, Treasurer, P.O. Box 353, Rocky Mount, N.C. 27801 
A copy of our report is filed with the Clerk of the House and is 

available for purchase from The Federal Election Commission, 
\'/ashington, D.C. 20515 



Ex-25 

Your vote will make the difference. 

Please join me in voting on Tuesday, July 27. I promise to be a 
Congressman of whom you can be proud. 

P.S . CALL TO ACTION 

Sincerely, 

Tim 
Valentine 

Please take the time to become personally involved in my 
campaign by listing below the names of five fr iends and 
neighbors, along with their telephone numbers, and call them on 
Tuesday, July 27 to make sure that each one votes. 

NAME TELEPHONE# 

Vallhtine 
For Congress 



Ex-26 

Vallhtine 
For Congress 

Durham Headquarters 
202 Corcoran Street 
Durham, N.C. 27701 

Dear Registered Voter, 

July 21 , 1982 

We ask that you consider the voting pattern and 
results of the June 29 primary. There were many many 
precincts in Durham that voted over 60% of their 
registration, while our precinct only voted around 45%. 

If you object to this domination-if you are · 
resentful of having others elect your officials-then you 
should vote on July 27. 

Join us in proving to ourselves that Tim Valentine 
can carry Club Boulevard precinct. 

Regards, 

Jim Dickson 



Ex-27 

From the Durham Morning Herald 

Precinct 

Club Blvd. 
Burton 
Hillside 
Whitted 
Shepard 
Hill andale 

June 30, 1982 

Valentine 

264 
9 
1 
1 
2 

302 

Michaux 

209 
1260 

883 
419 
744 
192 

Ramsey 

282 
14 

9 
5 
9 

313 

A Strong Voice For Our District 
Paid for by the Tim Volentine for Congress Committee. 

CT. Lone, Treasurer, P.O. Box 353, Rocky Mount, N.C. 27801 
A copy of our report is filed with the Clerk of the House and is 
available for purchase from The Federal Election Commission, 

Washington , D .C. 20515 



Ex-28 

DEFENDANT'S EXHIBIT 1 

STATE BOARD OF ELECTIONS 
SUITE 801 RALEIGH BUILDING 

5 WEST HARGETT STREET 
RALEIGH, NoRTH CAROLINA 27601 

ROBERT W. SPEARMAN 
C_HAIRMAN 

MEMBERS 

MRS. ELLOREE M. ERWIN 
CHARL01'T~: 

WILLIAM A. MARSH, JR. 
O Uim AM 

MRS. RUTH TURNER SEMASHKO 
HoRSE SHoE 

ROBERT W. SPEf\RMAN 

JOHN A. WALKER 
NoRTH WILK~:snoRo 

November 30, 1981 

SPECIAL MEMORANDUM 
SUBJECT: Increased Voter Registration 

FROM: Robert W Spearman, Chairman 
Alex K. Brock, Director 

TO: All County Board Members and Supervisors 

At its meeting on November 9, 1981, the State 
Board of Elections adopted and endorsed the goal of 
increased voter registration in North Carolina as a top Board 
priority. 

The Board has directed us to communicate with 
each of you about its interest and concern in this important 
area. 

A successful effort to increase voter registration 
will require pooling the efforts, talents, energy and ideas of 



Ex-29 

local board members, supervisors, elected officials, state 
board members and staff with the political parties, civic 
groups and all interested citizens. 

We would request that at your next local board 
meeting you consider what specific steps can be taken in 
your county and statewide to make it easier and more 
convenient for citizens to register to vote. We also request 
you provide our board with the voting age population in your 
county, based on the most recent U.S. census. 

We would very much appr eciate any guidance 
and suggestions you can give us as to steps the state board 
and its staff can take to increase registration, whether those 
be by adopting or altering regulations, recommending 
legislation to the General Assembly, sponsoring registration 
drives or other techniques. 

. We are aware that certain voter registration 
techniques work better in some areas than in others. Among 
the approaches that you may wish to consider using in your 
county are: 

1. Running public service spots on TV or radio 
telling citizens the specific times and places thay can 
register. 

2. Encourage local political parties to work with 
precinct judges, registrars and special registration commis­
sioners to have special voter registration days at community 
centers, schools and shopping centers. 

3. Request local county ( and municipal) officials 
to include information about how and where one can register 
in mailings that are routinely sent out from county or city 
offices ( e.g., with tax listing notices, water and sewer bills, 
etc.). 

4 . In counties where such a system is not 
already in place, work with local library officials and library 
trustees to have public library employees designated as 



Ex-30 

special library registration deputies. (This is already autho­
rized by G.S. 163-80 ( 6 ).) 

5. Use supervisors, deputy supervisors of elec­
tions and local election board members as registrars for 
special registration efforts in schools, community centers, 
nursing homes, etc. ( This is already authorized by G.S. 
163-35 and 163-80.) 

We very much look forward to working with you 
on voter registration and we would certainly appreciate any 
suggestions you can pass along to us. 

DUPLICATE THIS FOR ALL BOARD MEMBERS 



Ex-31 

DEFENDANT'S EXHIBIT 2 

STATE BOARD OF ELECTIONS 
SUITE 801 RALEIGH BUILDING 

5 WEST HARGETT STREET 
RALEIGH, NORTH C AROLINA 27601 

ROBERT W. SPEARMAN 
C H A IRMAN 

MRS. ELLOREE M. ERWIN 
C HARLOTI'E 

WILLIAM A. MARSH, .JR. 
D U RHA M 

MRS. RUTH TURNER SEMASHKO 
Hom;•; SHo•; 

ROBERT W. SPEARMAN 
R A L E J(;H 

JOHN A. WALKER 
NoRTH Wu.K•;~moRo 

December 14, 1981 

TO: NORTH CAROLINA COUNTY ELECTIONS BOARDS AND 
SUPERVISORS 

Recently questions have been raised concerning com­
pensation of registrars, judges and special registration 
commissioners in voter registration efforts. Often the 
questions have come up when a civic or community group 
desires to have a qualified person eligible to register voters 
present at a rally, picnic, dinner or some other community 
occasion. In such situations, the following principles should 
be followed. 

l. Under State law any registrar, judge of election or 
special registration commissioner can register voters any­
where in the county without regard to the precinct of the 
applicant unless the local board has restricted the authority 
of the registrar, judge or special commissioner. G.S. 173-67. 

The State Board strongly encourages the use of 
registrars, judges and special registration commissioners for 



Ex-32 

special registration efforts and suggests that any local board 
rules restricting their authority be reexamined. 

2. There is no state law requirement that registrars, 
judges or special registration commissioners be compensated 
for registering voters. Frequently registrars and judges 
register voters (as opposed to performing their election dey­
duties) on a volunteer basis without pay. (However, some 
county boards do pay for special registration work performed 
at public libraries or other places, and it is perfectly proper 
to do so.) 

3. Private groups may not compensate registrars, 
election judges, or special registration commissioners. G.S. 
163-275. 

4. If a private group (e.g. civic club, community 
association, etc.) is willing to or desires to reimburse a 
county for the cost of paying registrars for special registra­
tion efforts it may properly do so. The proper procedure to 
follow is for the group to make a contribution to the board of 
county commissioners for the purpose of special voter 
registration and the commissioners could then appropriate 
the funds to the local Board of Elections for such purpose. 

Robert W. Spearman 
Chairman, State Board of 
Elections 

Alex K. Brock 
Executive Secretary-Director, 
State Board of Elections 

Senior Deputy Attorney General 

DUPLICATE FOR ALL BOARD MEMBERS 



Ex-33 

DEFENDANT'S EXHIBIT 3 

STATE BOARD OF ELECTIONS 
SUITE 801 RALEIGH BUILDING 

5 WEST H ARGETT STREET 
RALEIGH, NORTH CAROLINA 27601 

ROBERT W. SPEARMAN 
CHAIRMAN 

MRS. ELLOREE M. ERWIN 
C HAKL( YJ"TE 

WILLIAM A. MARSH, JR. 
DUJmAM 

MRS. RUTH TURNER SEMASHKO 

ROBERT W. SPEARMAN 
R ALEWH 

JOHN A. WALKER 
NORTH WILK~;SIIOIUI 

January 29, 1982 

TO: COUNTY BOARD MEMBERS AND SUPERVISORS 

FROM: BOB SPEARMAN, CHAIRMAN 
ALEX BROCK, EXECUTIVE DIRECTOR 

SUBJECT: CITIZEN AWARENESS YEAR AND VOTER 
REGISTRATION 

At the request of the State Board of Elections, 
Governor James Hunt has designated 1982 as a Citizen 
Awareness Year in which a maximum effort will be made to 
increase North Carolina voter registration. 

The State Board will sponsor two major voter 
registration drives, from April 15, 1982 to July 5 , 1982 
before the primary and from September l to October 4 
(when registration closes for the general election.) 

The voter registration drive is officially spon­
sored and is nonpartisan. All political parties and civic 
groups are invited and encouraged to participate. 



Ex-34 

Obviously, the success of this effort will depend 
very much upon you because you are the public officials most 
familiar with the election process and closest to its da;y-to­
da;y operation. 

There will be two main thrusts to the voter 
registration drive: ( 1) Maximum publicity of existing voter 
registration opportunities and ( 2) Provision of special 
registration opportunities to maximize participation. 

The State Board intends to take all possible steps 
to maximize statewide publicity, including holding press 
conferences and providing public service spots to radio and 
television stations. Wf3 request that your local board take 
similar steps in your county or municipality. Specifically, you 
may wish to consider the following: 

Check with local T.V. and radio stations to 
determ:i;ne if they will produce and broadcast public service 
spots telling county citizens when and where they can 
register to vote. ( The spot announcements can be made by 
different board members.) 

Issue press releases on Citizen Awareness Year 
in your area and registration opportunities. 

Post signs or notices with registration informa­
tion in public places ( e.g. county offices , stores, community 
bulletin boards.) 

Check with county and municipal officials to see 
if they would agree to have basic voter registration informa­
tion included with routine official mailings ( e.g. with tax 
notices or municipal water bills.) 

Special Registration Opportunities. 

In addition to publicizing existing registration 
opportunities, we need to take extra steps to reach groups 
whose registration has historically been low. Situations vary 
in different areas of the State, but frequently groups with low 
registration include elderly citizens, young people, and 



Ex-35 

minority groups. We request you consider using the following 
outreach techniques during Citizen Awareness Year, particu­
larly from April 15, 1982 to July 5 , 1982 and September 1 to 
October 4 , 1982. 

1. Staff registration tables in evening hours at 
places where large groups of people congregate ( shopping 
centers are often excellent.) 

2. Have a "registration day" in the spring and 
again in the fall in local public high schools and community 
colleges; on these days send registrars and commissioners to 
register students and faculty at their educational institutions. 

3. Send registrars or commissioners for special 
registration events to residential areas where registration is 
low. These may include nursing homes, public housing or 
mobile home parks. 

4 . Upon request; supply registrars or commis­
sioners for special events being run by community groups, 
such as banquets, dinners, picnics, athletic contests, church 
suppers, etc. (Very frequently, this can be done without any 
cost to the board because registrars or commissioners will 
donate their time and not expect to be paid.) 

We expect that local boards will receive requests 
from political parties and community groups for assistance 
in special registration efforts during Citizens Awareness 
Year. 

When you receive such requests , try to be as 
helpful as you can in answering questions, supplying voter 
registration information and where necessary, helping to 
find registrars, judges, and special registration commis­
sioners who can assist in registering voters at special 
events. 





Paid Pol. Adv. 

WHAT NORTH-CAROLINA NEWSPAPERS 
SAY ABOUT VOTER REGISTRATION 

~.~~~::.:~... . .. ~ . . 

~, . . :f 

GOV. HUNT, REV. JACKSON MEET - Governor Jim Hunt and the Rev. 
Jesse Jackson met in the Executive Mansion March 11 to discuss a number of 
mutuai concerns. including voter registration . .. 

The Carolinian, 3-18-82 

"He (Jesse- Jackson} said Gov. Jim Hunt, an expected 
Senate candidate in 1984, had 'a limited future-unless 
we register.' "" 

Greensboro Da ily New~. 5-16-83 

...... 
~~we must register at least 200,000 black voters in North 
Carolina in the next two months." (Jesse Jackson) 

New, and Ob~erver. 4-22-83 

~~Gov. james B. Hunt, Jr. wants the State Board of 
Elections to boost minority voter registration in 
North Carolina ... " t :Pf ·Chapel Hill NevnpapPr. 11-10-81 

Ask Yourself: 
Is This A Proper Use Of Taxpayer Funds? 

Ex-36 

PLAINTIFF'S 
EXHIBIT 
..Pc. ; 

• 





Ex-37 

GINGLES EXHIBIT #56 

Mecklenburg County-Demographic Data 

White Black 
Population 291,442 107,006 
Percent of Population 72.1 26.5 

Percent of Population Below 
Poverty 5.5 25.7 

Percent of Family Income 
over $20,000 61.7 27.9 

Mean Income 27,209 15,519 
Ratio Black to White Mean 

Income 57.0% 

Total Number of Housing 
Units 111,223 34,209 

Number of Renter Occupied 36,94~ 2,056 
Percent Renter Occupied 33.2 60.1 
Percent Units with No Vehi-

cle Available 5.0 26.5 

Percent Over 25 with 
Eighth Grade Education 
or Less 9.9 25.0 

Percent Voting Age Popula-
tion that is Black (1980) 24.0 

Percent Voters that is Black 
(1980) 16.9 

Total 
404,270 

10.9 

53.6 
24,462 

10.0 



/ 

/ Ex-38 

GINGLES EXHIBIT #57 

Forsyth County-Demographic Data 

White Black 
Population 
Percent of Population 

Percent of Population Below 
Poverty 

Percent of Family Income 
over $20,000 

Mean Income 
Ratio Black to White Mean 

Income 

Total Number of Housing 
Units 

Number of Renter Occupied 
Percent Renter Occupied 
Percent Units with No Vehi-

cle Available 

Percent Over 25 with 
Eighth Grade Education 
or Less 

Percent Voting Age Popula­
tion that is Black (1980) 

Percent Voters that is Black 
(1980) 

182,647 59,403 
75.0 24.4 

6.9 25.6 

56.2 28.6 
25,355 15,101 

59.56% 

69,699 19,885 
19,320 11,934 

27.7 60.0 

5.9 27.4 

16.7 26.6 

22.0 

20.3 

Total 
243,683 

11.6 

50.2 
23,188 

10.7 



Ex-39 

GINGLES EXHIBIT #58 

Durham County-Demographic Data 

Population 
Percent of Population 

Percent of Population Below 
Poverty 

Percent of Family Income 
over $20,000 

Mean Income 
Ratio Black to White Mean 

Income 

Total Number of Housing 
Units 

Number of Renter Occupied 
Percent Renter Occupied 
Percent Units with No Vehi-

cle Available 

Percent Over 25 with 
Eighth Grade Education 
or Less 

Percent Voting Age Popula-
tion that is Black (1980) 

Percent Voters that is Black 
(1980) 

White Black 
95,818 55,424 

62.7 36.3 

7~ 6 24.9 

57.8 28.5 
24,984 15,357 

-61.47% 

36,792 18,343 
13,953 11,462 

37.9 62.5 

6.9 25.2 

14.6 26.6 

33.6 

24.9 

Total 
152,785 

14.0 

4"1.9 
21,719 

13.0 



Ex-40 

GINGLES EXHIBIT #59 

Wake County-Demographic Data 

White Black 
Population 
Percent of Population 

Percent of Population Below 
Poverty 

Percent of Family Income 
over $20,000 

Mean Income 
Ratio Black to White Mean 

Income 

Total Number of Housing 
Units 

Number of Renter Occupied 
Percent Renter Occupied 
Percent Units with No Vehi-

cle Available 

Percent Over 25 with 
Eighth Grade Education 
or Less 

Percent Voting Age Popula­
tion that is Black (1980) 

Percent Voters that is Black 
(1980) 

231 ,561 65,553 
76.8 21.8 

6.2 23.4 

63.7 28.7 
26,893 15,347 

57.07% 

85,664 19,793 
29,609 11 ,021 

34.6 55.7 

4.5 21.0 

9.3 28.2 

Total 
301 ,327 

10.0 

56.8 
24,646 

7.6 



Ex-41 

GINGLES EXHIBIT #60 

Wilson County-Demographic Data 

White Black 
Population 39,943 22,981 
Percent of Population 63.3 36.4 

Percent of Population Below 
Poverty 9.6 37.8 

Percent of Family Income 
over $20,000 45.5 17.1 

Mean Income 21,687 12,241 
Ratio Black to White Mean 

Income 56.44% 

Total Number of Housing 
Units 14,725 6,781 

Number of Renter Occupied 4,818 4,368 
Percent Renter Occupied 32.7 64.4 
Percent Units with No Vehi-

cle Available 7.1 29.1 

Percent Over 25 with 
Eighth Grade Education 
or Less 23.0 44.2 

Percent Voting Age Popula-
tion that is Black (1980) 32.4 

Percent Voters that is Black 
(1980) 23.0 

Total 
63,132 

20.0 

36.5 
18,732 

14.0 

14.0 



Ex-42 

GINGLES EXHIBIT #61 

Edgecombe County-Demographic Data 

Population 
Percent of Population 

Percent of Population Below 
Poverty 

Percent of Family Income 
over $20,000 

Mean Income 
Ratio Black to White Mean 

Income 

Total Number of Housing 
Units 

Number of Renter Occupied 
Percent Renter Occupied 
Percent Units with No Vehi-

cle Available 

Percent Over 25 with 
Eighth Grade Education 
or Less 

Percent Voting Age Popula-
tion that is Black (1980) 

Percent Voters that is Black 
(1980) 

White Black 
27,428 28,433 

49.0 50.8 

9.6 30.5 

44.2 20.2 
20,476 13,592 

-66.38% 

10,246 8,117 
2,782 4,258 
27.2 52.5 

7.7 26.2 

23.8 40.3 

46.7 

34.6 

Total 
55,988 

20.2 

33.3 
17,360 

16.0 



Ex-43 

GINGLES EXHIBIT #62 

Nash County-Demographic Data 

White Black 
Population 44,745 22,089 
Percent of Population 66.6 32.9 

Percent of Population Below 
Poverty 8.9 41.8 

Percent of Family Income 
over $20,000 46.7 13.9 

Mean Income 21,785 11,434 
Ratio Black to White Mean 

Income 52.49% 

Total Number of Housing 
Units 16,982 6,391 

Number of Renter Occupied 4,933 3,763 
Percent Renter Occupied 29.0 58.9 
Percent Units with No Vehi-

cle Available 6.7 27.2 

Percent Over 25 with 
Eighth Grade Education 
or Less 

Percent Voting Age Popula-
tion that is Black (1980) 29.4 

Percent Voters that is Black 
(1980) 13.2 

Total 
67,153 

19.9 

37.5 
18,937 

12.3 



Ex-44 

GINGLES EXHIBIT #63 

Halifax County-Demographic Data 

White Black 
Population 27,559 26,053 
Percent of Population 49.8 47.1 

Percent of Population Below 
Poverty 12.6 47.8 

Percent of Family Income 
over $20,000 37.9 12.9 

Mean Income 19,042 10,465 
Ratio Black to White Mean 

Income -54.96% 

Total Number of Housing 
Units 10,680 7,201 

Number of Renter Occupied 2,800 3,520 
Percent Renter Occupied 26.2 48.9 
Percent Units with No Vehi-

cle Available 10.2 32.3 

Percent Over 25 with 
Eighth Grade Education 
or Less 25.6 51.5 

Percent Voting Age Popula-
tion that is Black (1980) 

Percent Voters that is Black 44.0 
(1980) 35.2 

Total 
55,286 

27.1 
15,479 

19.0 



Ex-45 

GINGLES EXHIBIT #64 

Northampton County-Demographic Data 

White Black 
Population 8,824 13,709 
Percent of Population 39.1 60.7 

Percent of Population Below 
Poverty 11.6 38.2 

Percent of Family Income 
over $20,000 34.9 15.3 

Mean Income 19,964 12,942 
Ratio Black to White Mean 

Income 64.83% 

Total Number of Housing 
Units 3,248 3,849 

Number of Renter Occupied 549 1,261 
Percent Renter Occupied 16.9 32.8 
Percent Units with No Vehi-

cle Available 10.5 27.9 

Percent Over 25 with 
Eighth Grade Education 
or Less 23.1 54.6 

Percent Voting Age Popula-
tion that is Black (1980) 56.2 

Percent Voters that is Black 
(1980) 51.4 

Total 
22,584 

28.1 

24.0 
16,080 

19.9 



Ex-46 

GINGLES EXHIBIT #65 

Hertford County-Demographic Data 

White Black 
Population 10,285 12,810 
Percent of Population 44.0 54.8 

Percent of Population Below 
Poverty 10.4 34.7 

Percent of Family Income 
over $20,000 41.8 20.5 

Mean Income 20,465 13,194 
Ratio Black to White Mean 

Income 64.47% 

Total Number of Housing 
Units 3,727 3,709 

Number of Renter Occupied 950 1,452 
Percent Renter Occupied 25.5 39.1 
Percent Units with No Vehi-

cle Available 10.0 28.1 

Percent Over 25 with 
Eighth Grade Education 
or Less 21.9 48. 1 

Percent Voting Age Popula-
. tion that is Black (1980) 56.2 

Percent Voters that is Black 
(1980) 51.4 

Total 
23,368 

24.3 

31.2 
16,946 

19.2 



Ex-47 

GINGLES EXHIBIT #66 

Gates County-Demographic Data 

White Black 
Population 4,192 4,664 
Percent of Population 47.2 52.6 

Percent of Population Below 
Poverty 7.9 30.5 

Percent of Family Income 
over $20,000 43.4 22.1 

Mean Income 21 ,025 13,204 
Ratio Black to White Mean 

Income -62.8% 

Total Number of Housing 
Units 1,605 1,274 

Number of Renter Occupied 265 343 
Percent Renter Occupied 16.5 26.9 
Percent Units with No Vehi-

cle Available 7.2 21.9 

Percent Over 25 with 
Eighth Grade Education 
or Less 21.3 43.4 

Percent Voting Age Popula-
tion that is Black (1980) -49.4 

Percent Voters that is Black 
(1980) -47.8 

Total 
8,875 

19.7 

33.4 
17,380 

13.7 



Ex-48 

GINGLES EXHIBIT #67 

Martin County-Demographic Data 

White Black 
Population 
Percent of Population 

Percent of Population Below 
Poverty 

Percent of Family Income 
over $20,000 

Mean Income 
.Ratio Black to White Mean 

Income 

Total Number of Housing 
Units 

Number of Renter Occupied 
Percent Renter Occupied 
Percent Units with No Vehi-

cle Available 

Percent Over 25 with 
Eighth Grade Education 
or Less 

Percent Voting Age Popula­
tion that is Black (1980) 

Percent Voters that is Black 
(1980) 

*not available 

14,334 11,555 
55.2 44.5 

10.8 

* 
* 

* 
* 
* 

* 

* 

40.3 

* 
* 

25.2 47.9 

40.6 
33.1 

Total 
25,948 

24.1 

* 
* 



Ex-49 

GINGLES EXHIBIT #68 

Bertie County-Demographic Data 

White Black 
Population 8,488 12,441 
Percent of Population 40.6 59.2 

Percent of Population Below 
Poverty 13.2 40.7 

Percent of Family Income 
over $20,000 32.0 12.8 

Mean Income 17,649 12,502 
Ratio Black to White Mean 

Income 70.8% 

Total Number of Housing 
Units 3,346 3,533 

Number of Renter Occupied 678 1,293 
Percent Renter Occupied 20. 3 36.6 
Percent Units with No Vehi-

cle Available 8.8 24.2 

Percent Over 25 with 
Eighth Grade Education 
or Less 28.8 45.1 

Percent Voting Age Popula-
tion that is Black (1980) 54.5 

Percent Voters that is Black 
(1980) 44.2 

Total 
21 ,024 

29.4 

22.0 
15,008 

16.6 



Ex-50 

GINGLES EXHIBIT #69 

Washington County-Demographic Data 

White Black 
Population 8,346 6,410 
Percent of Population 56.4 43.3 

Percent of Population Below 
Poverty 10.9 35.9 

Percent of Family Income 
over $20,000 48.5 22.4 

Mean Income 20,868 13,019 
Ratio Black to White Mean 

Income 62.39% 

Total Number of Housing 
Units 3,052 1,670 

Number of Renter Occupied 596 624 
Percent Renter Occupied 19.5 37.4 
Percent Units with No Vehi-

cle Available 7.6 30.1 

Percent Over 25 with 
Eighth Grade Education 
or Less 22.2 43.9 

Percent Voting Age Popula-
tion that is Black (1980) 39.1 

Percent Voters that is Black 
(1980) 34.0 

Total 
14,801 

21.7 

38.9 
17,998 

15.6 



Ex-51 

GINGLES EXHIBIT #70 

Chowan County-Demographic Data 

White Black . 
Population 7,294 5,210 
Percent of Population 58.1 41.5 

Percent of Population Below 
Poverty 8.8 45.4 

Percent of Family Income 
over $20,000 41.5 9.5 

Mean Income 20,622 10,704 
Ratio Black to White Mean 

Income 51% 

Total Number of Housing 
Units 2,765 1,559 

Number of Renter Occupied 587 738 
Percent Renter Occupied 21.2 47.3 
Percent Units with No Vehi-

cle Available 7.5 30.3 

Percent Over 25 with 
Eighth Grade Education 
or Less 23.2 48.9 

Percent Voting Age Popula-
tion that is Black (1980) 38.1 

Percent Voters that is Black 
(1980) 31.2 

Total 
12,558 

24.0 

29.1 
16,877 

15.8 



Ex-52 

GINGLES EXHIBIT #70A 

North Carolina-Demographic Data 

White Black Total 
Population 4,460,570 1,319,054 5,881, 766 
Percent of Population 75.8 22.4 

Percent of Population 
Below Poverty 10.0 30.4 14.8 

Percent of Family In-
come over $20,000 43.8 21.5 39.2 

Mean Income 21 ,008 13,648 19,544 
Ratio Black to White 

Mean Income 64.9% 

Total Number of 
How~ing Units 1,624,372 391,379 

Number of Renter 
Occupied 442,060 191,925 

Percent Renter 
Occupied 27.2 49.03 

Percent Units with No 
Vehicle Available 7.3 25.1 10.8 

Percent Over 25 with 
Eighth Grade Educa-
tion or Less 22.0 34.6 

Percent Voting 



Ex-53 

DEFENDANT'S EXHIBIT 1 

STATE BOARD OF ELECTIONS 
SUITE 801 RALEIGH BUILDING 

5 WEST HARGETT STREET 
RALEIGH, NORTH CAROLINA 27601 

ROBERT W. SPEARMAN 
CHAIRMAN 

MRS. ELLOREE M. EI{W!N 
CIL\IU.tYIT~: 

WILLIAM A. MARSH • .JR. 
D UIUIAM 

MRS. RUTH TURNER SEMASHKO 
HoltSE Sum: 

ROBERT W. SPEARMAN 
RALEH:II 

.JOHN A. WALKER 
NoRTH WH .K~:sBOIW 

November 30, 1981 

SPECIAL MEMORANDUM 

SUBJECT: Increased Voter Registration 

FROM: Robert W. Spearman, Chairman 
Alex K. Brock, Director 

TO: All County Board Members and Supervisors 

At its meeting on November 9, 1981, the State 
Board of Elections adopted and endorsed the goal of 
increased voter registration in North Carolina as a top Board 
priority. 

The Board has directed us to communicate with 
each of you about its interest and concern in this important 
area. 

A successful effort to increase voter registration 
will require pooling the efforts, talents, energy and ideas of 



Ex-54 

local board members, supervisors, elected officials, state 
board members and staff with the political parties, civic 
groups and all interested citizens. 

We would request that at your next local board 
meeting you consider what specific steps can be taken in 
your county and statewide to make it easier and more 
convenient for citizens to register to vote. We also request 
you provide our board with the voting age population in your 
county, based on the most recent U.S. census. 

We would very much appreciate any guidance 
and suggestions you can give us as to steps the state board 
and its staff can take to increase registration, whether those 
be by adopting or altering regulations, recommending 
legislation to the General Assembly, sponsoring registration 
drives or other techniques. 

We are aware that certain voter registration 
techniques work better in some areas than in others. Among 
the approaches that you may wish to consider using in your 
county are: 

l . Running public service spots on TV or radio 
telling citizens the specific times and places thay can 
register. 

2. Encourage local political parties to work with 
precinct judges, registrars and special registration commis­
sioners to have special voter registration days at communit:y 
centers, schools and shopping centers. 

3. Request local county ( and municipal) officials 
to include information about how and where one can register 
in mailings that are routinely sent out from county or city 
offices ( e.g., with tax listing notices, water and sewer bills, 
etc.). 

4 . In counties where such a system is not 
already in place, work with local library officials and library 
trustees to have public library employees designated as 



Ex-55 

special library registration deputies. (This is already autho­
rized by G.S. 163-80 (6).) 

5 . Use supervisors, deputy supervisors of elec­
tions and local election board members as registrars for 
special registration efforts in schools, community centers, 
nursing homes, etc. (This is already authorized by G.S. 
163-35 and 163-80.) 

We very much look forward to working with you 
on voter registration and we would certainly appreciate any 
suggestions you can pass along to us. 

DUPLICATE THIS FOR ALL BOARD MEMBERS 



Ex-56 

DEFENDANT'S EXHIBIT 2 

STATE BOARD OF ELECTIONS 
SUITE 801 RALEIGH BUILDING 

5 WEST HARGETT STREET 
RALEIGH, NoRTH CAROLINA 27601 

ROBERT W. SPEARMAN 
CHAIRMAN 

MRS. ELLOREE M. ERWIN 
CHARLOT'J't; 

WILLIAM A. MARSH • .JR. 
DIJIUIAM 

MRS. RUTH TURNER SEMASHKO 
HoRs•; SHo•; 

ROBERT W. SPEARMAN 
RAL•;ual 

.JOHN A. WALKER 
NoRTH WILKt:sBolto 

December 14, 1981 

TO: NORTH CAROLINA COUNTY ELECTIONS BOARDS AND 
SUPERVISORS 

Recently questions have been raised concerning com­
pensation of registrars, judges and special registration 
commissioners in voter registration efforts. Often the 
questions have come up when a civic or community group 
desires to have a qualified person eligible to register voters 
present at a rally, picnic, dinner or some other community ' 
occasion. In such situations, the following principles should 
be followed. 

1. Under State law any registrar, judge of election or 
special registration commissioner can register voters any­
where in the county without regard to the precinct of the 
applicant unless the local board has restricted the authority 
of the registrar, judge or special commissioner. G.S. 173-67. 

The State Board strongly encourages the use of 
registrars, judges and special registration commissioners for 



Ex-57 

special registration efforts and suggests that any local board 
rules restricting their authority be reexamined. 

2. There is no state law requirement that registrars, 
judges or special registration commissioners be compensated 
for registering voters. Frequently registrars and judges 
register voters ( as opposed to performing their election day 
duties ) on a volunteer basis without pay. (However, some 
county boards do pay for special registration work performed 
at public libraries or other places, and it is perfectly proper 
to do so.) 

3 . Private groups may not compensate registrars, 
election judges, or special registration commissioners. G.S. 
163-275. 

4. If a private group ( e.g. civic club, community 
association, etc.) is willing to or desires to reimburse a 
county for the cost of paying registrars for special registra­
tion efforts it may properly do so. The proper procedure to 
follow is for the group to make a contribution to the board of 
county commissioners for the purpose of special voter 
registration and the commissioners could then appropriate 
the funds to the local Board of Elections for such purpose. 

Robert W. Spearman 
Chairman, State Board of 
Elections 

Alex K. Brock 
Executive Secretary-Director, 
State Board of Elections 

Senior Deputy Attorney General 

DUPLICATE FOR ALL BOARD MEMBERS 



Ex-58 

DEFENDANT'S EXHIBIT 3 

STATE BOARD OF ELECTIONS 
SUITE 801 RALEIGH BUILDING 

5 WEST HARGETT STREET 
RALEIGH, NoRTH CAROLINA 27601 

ROBERT W. SPEARMAN 
CUAIIOIAN 

MRS. ELLOREE M. ERWIN 
CuAttLO'M'~; 

WILLIAM A. MARSH. JR. 
U u ttuAM 

MRS. RUTH TURNER SEMASHKO 
HOI{SE SHOE 

ROBERT W. SPEARMAN 
RALEIGU 

.JOHN A. WALKER 
NottTU WtLKEsllotto 

January 29, 1982 

TO: COUNTY BOARD MEMBERS AND SUPERVISORS 

FROM: BOB SPEARMAN, CHAIRMAN 
ALEX BROCK, EXECUTIVE DIRECTOR 

SUBJECT: CITIZEN AWARENESS YEAR AND VOTER 
REGISTRATION 

At the request of the State Board of Elections, 
Governor James Hunt has designated 1982 as a Citizen 
Awareness Year in whic:q a maximum effort will be made to 
increase North Carolina voter registration. 

The State Board will sponsor two major voter 
registration drives, from April 15, 1982 to July 5, 1982 
before the primary and from September 1 to October 4 
(when registration closes for the general election.) 

The voter registration drive is officially span-



Ex-59 

sored and is nonpartisan. All political parties and civic 
groups are invited and encouraged to participate. 

Obviously, the success of this effort will depend 
very much upon you because you are the public officials most 
familiar with the election process and closest to its day-to­
day operation. 

There will be two main thrusts to the voter 
registration drive: ( l ) Maximum publicity of existing voter 
registration opportunities and (2) Provision of special 
registration opportunities to maximize participation. 

The State Board . intends to take all possible steps 
to maximize statewide publicity, including holding press 
conferences and providing public service spots to radio and 
television stations. We request that your local board take 
similar steps in your county or municipality. Specifically, you 
may wish to consider the following: 

Check with local T.V. and radio stations to 
determine if they will produce and broadcast public service 
spots telling county citizens when and where they can 
register to vote. (The spot announcements can be made by 
different board members.) 

Issue press releases on Citizen Awareness Year 
in your area and registration opportunities. 

Post signs or notices with registration informa­
tion in public places (e.g. county offices, stores, community 
bulletin boards.) 

· Check with county and municipal officials to see 
if they would agree to have basic voter registration informa­
tion included with routine official mailings (e.g. with tax 
notices or municipal water bills. ) 

Special Registration Opportunities. 

In addition to publicizing existing registration 
opportunities, we need to take extra steps to reach groups 



Ex-60 

whose registration has historically been low. Situations vary 
in different areas of the State, but frequently groups with low 
registration include elderly citizens, young people, and 
minority groups. We request you consider using the following 
outreach techniques during Citizen Awareness Year, particu­
larly from April 15, 1982 to July 5, 1982 and September 1 to 
October 4, 1982. 

l. Staff registration tables in evening hours at 
places where large groups of people congregate ( shopping 
centers are often excellent. ) 

2 . Have a "registr ation day" in the spring and 
again in the fall in local public high schools and community 
colleges; on these days send registrars and commissioners to 
register students and faculty at their educational institutions. 

3 . Send registrars or commissioners for special 
registration events to residential areas where registration is 
low. These may include nursing homes, public housing or 
mobile home parks. 

4. Upon request; supply registrars or commis­
sioners for special events being run by community groups, 
such as banquets, dinners, picnics, athletic contests, church 
suppers, etc. (Very frequently, this can be done without any 
cost to the board because registrars or commissioners will 
donate their time and not expect to be paid.) 

We expect that local boards will receive requests 
from political parties and community groups for assistance 
in special registration efforts during Citizens Awareness 
Year. 

When you receive such requests , try to be as 
helpful as you can in answering questions, supplying voter 
registration information and where necessary, helping to 
find registrars, judges, and special registration commis­
sioners who can assist in registering voters at special 
events. 



Ex-61 

DEFENDANT'S 
EXHIBIT 

14 

North Carolina Voter Registration February, 
1982-0ctober, 1982 

Non-White 
White Voters Voters All Voters 

Registered Registered Registered 

2/9/82 2,081 ,836 401,962 2,483,798 
3/31/82 2,108,211 -416,735 
6/1/82 2,160,579 455,368 
10/4/82 2,201 ,189 470,638 2,671,827 
Absolute 
Increase 
2/9/82 to 6/1/82 78,743 53,406 132,149 
% increase 

_ 2/9/82 to 6/1/82 3.7% 13.2% 5% 
:.Absolute 

Increase 
2/9/82 to 10/4/82 119,353 68,676 188,029 
% increase 
2/9/82 to 10/4/82 5.7% 17% 7.5% 

* * * * * * 

Approximate Percent of Voting Age Population* 
Registered 

2/9/82 
6/1182 
10/4/82 

58.6% 
61.7% 
63.1% 

*based upon February, 1982 population statistics. 



/' 
/ 

/ Ex-62 

Voter Registration Increases For Selected Counties From 
February 1982 to October 1982 

Increase Increase Total % 
White Non-White Increase 

Registered % Registered % All 
County Voters Increase Voters Increase Voters 
---
Forsyth 4,105 4% 2,880 13% 6% 
Mecklenburg 6,493 4% 2,896 9% 5% 
Wake 4,416 4% 2,292 11% 5% 

Durham 2,246 5% 3,565 21% 9% 
Nash 802 4% 1,620 37% 10% 
Edgecombe 215 2% 3,310 54% 19% 
Wilson 952 5% 2,193 46% 14% 
Halifax 676 5% 2,507 36% 16% 

Bertie 431 10% 1,126 32% 20% 
Chowan 131 3% 223 14% 6% 
Gates 141 6% 451 21% 13% 
Hertford 456 9% 1,143 31% 18% 
Martin 202 3% 539 16% 7% 
Northampton 1,029 22% 1,903 42% 32% 
Washington 195 4% 403 18% 9% 



Ex-63 

DEFENDANT'S EXHIBIT 15 

STATE BOARD OF ELECTIONS 
SUITE 801 RALEIGH BUILDING 

5 WEST HARGETT STREET 
RALEIGH, NoRTH CAROLINA 27601 

ROBERT W. SPEARMAN 
C HAIRMAN 

MRS. ELLOREE M. ERWIN 
C H,\IU.(YITE 

WILLIAM A. MARSH, .JR. 
D URHAM 

MRS. RUTH TURNER SEMASHKO 
HoRsE Sum~ 

ROBERT W. SPEARMAN 
RAL~~ u ; u 

.JOHN A. WALKER 
No RTH WII .IH;suo Ro 

January 14, 1983 

Governor James B. Hunt 
State Capital 
Raleigh, North Carolina 

Lieutenant Governor James 
Green 

Legislative Office Building 
Raleigh, North Carolina 

Speaker Liston Ramsey 
North Carolina House of 

Representatives 
Raleigh, North Carolina 

Representative J . Worth 
Gentry 

North Carolina House of 
Representatives 

Raleigh, North Carolina 

Senator Wilma C. Woodard 
North Carolina State Senate 
Raleigh, North Carolina 

Gentlemen and Senator Woodard: 

In recent months the North Carolina Board of 
Elections has given careful consideration to possible recom­
mendations to you concerning the conduct and administra­
tion of the election laws. 



Ex-64 

We have received proposals from interested citizens, 
political parties, county election boards and other groups. 

We wish to recommend the following six items for 
legislative action in the 1983 Session. As you are aware the 
State board and County Boards have in the last year made 
extensive efforts to ease access to voter registration, and our 
recommendations include several items in this very impor­
tant area. 

l. Authorization to permit the State Election Board 
to name Department of Motor Vehicle drivers license 
examiners as special registration commissioners. 

This would enable citizens to complete voter registra­
tion application when they obtain or renew their driver's 
license. Such a system has worked very well in Michigan; it 
has recently been recommended by Governor Robbin 
Virginia and voters in Arizona adopted it by referendum in 
the recent November election. This proposal is supported by 
the North Carolina Division of Motor Vehicles. 

2. Legislation to permit voter registration at public 
high schools with school librarians as registrars. 

We are all aware that registration rates among young 
people are low and need to be raised. This proposal should 
lead to substantial registration increases. 

3 . Require public libraries to permit voter registra-
tion. Public library registration has been extremely success­
ful in many counties in the state. The concept is strongly 
supported by county election boards. 

4 . Legislation providing for simultaneous issuance 
of absentee ballot application and absentee ballot itself. 

This reform would reduce postage costs and make it 
easier for qualified persons to vote absentee without 
eliminating any of our existing safeguards. 

5. Amendment of G.S. 163-22.1 to permit State 
Elections Board to order a new election when legally 



Ex-65 

appropriate, after hearings have been held and findings of 
fact made by a county board. 

This would clarify the authority of the State Board to 
order a new election without unnecessarily duplicating 
hearings already held by a county board. The amendment 
would save time, money and expedite the resolution of 
election contests. 

6 . Authorization of constitutional amendment to 
grant State Board authority to issue regulations to deal with 
"out of precinct" voting problem. 

Citizens and election officials alike are frustrated by 
the situation where persons move from one precinct to 
another within a county but fail to transfer their registra­
tion. When registration has not been changed by election day 

• citizens either lose their right to vote or vote improperly in 
their old precinct. A constitutional amendment is apparently 

! needed here because the 30 day residency requirement for a 
precinct for eligibility to vote is a constitutional_ ~equirement. 

* * * 
In addition to these six proposals we also suggest that 

the appropriate House and Senate committees may well wish 
to review the operation and administration of Article 23 and 
24 or Chapter 163 regarding municipal elections and 
consider whether all municipalities should contract to have 
municipal elections administered by county election boards. 

We look forward to working with you on these matters. 

With best wishes, 

RWS/ehd 

Robert W Spearman 
Chairman, State Board of Elections 

Alex K. Brock 
Executive Director 
State Board of Elections 

cc: Members, State Board of Elections 
James Bullock 



• 






	NAACP0070
	NAACP0071
	NAACP0072
	NAACP0073
	NAACP0074
	NAACP0075
	NAACP0076
	NAACP0077
	NAACP0078
	NAACP0079
	NAACP0080
	NAACP0081
	NAACP0082
	NAACP0083
	NAACP0084
	NAACP0085
	NAACP0086
	NAACP0087
	NAACP0088
	NAACP0089
	NAACP0090
	NAACP0091
	NAACP0092
	NAACP0093
	NAACP0094
	NAACP0095
	NAACP0096
	NAACP0097
	NAACP0098
	NAACP0099
	NAACP0100
	NAACP0101
	NAACP0102
	NAACP0103
	NAACP0104
	NAACP0105
	NAACP0106
	NAACP0107
	NAACP0108
	NAACP0109
	NAACP0110
	NAACP0111
	NAACP0112
	NAACP0113
	NAACP0114
	NAACP0115
	NAACP0116
	NAACP0117
	NAACP0118
	NAACP0119
	NAACP0120
	NAACP0121
	NAACP0122
	NAACP0123
	NAACP0124
	NAACP0125
	NAACP0126
	NAACP0127
	NAACP0128
	NAACP0129
	NAACP0130
	NAACP0131
	NAACP0132
	NAACP0133
	NAACP0134
	NAACP0135
	NAACP0136
	NAACP0137
	NAACP0138
	NAACP0139
	NAACP0140
	NAACP0141
	NAACP0142
	NAACP0143