Defendant's Post-Trial Brief

    IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
RALEIGH DIVISION

RALPH GINGLES, et al.,
No. 81-803-CIV—5
Plaintiffs,
vs.
RUFUS EDMISTEN, et al.,
Defendants.
—and—
ALAN V. PUGH, et al.,
Plaintiffs, No. 81-1066-CIV-5
vs.

JAMES B. HUNT, JR., et al.,

Defendants.

Vvvvvvvvvvvvvvvvvvvvvvv

 

DEFENDANTS' POST-TRIAL BRIEF

 

Introduction

The plaintiffs have alleged that the multimember
district configuration in certain counties of the State deny
black voters equal access to the electoral process. This
claim of unequal access to the political process is clearly

disingenuous. The gravemen of the plaintiffs' case and the

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focus of their proof is that the districts as drawn in Durham,
Forsyth, Mecklenburg and Wake Counties do not guarantee that
a black will always be elected. The plaintiffs' expert, Dr.
Bernard Grofman, criticized the multimember configurations on
the grounds that they did not guarantee that black candidates
would be as successful in 1984 as they were in 1982. GROFMAN,
T. _3, 103. Nothing in the legislative history of Section 2,
however, evidences a Congressional intent to insure safe seats
for racial minorities. The thrust of the statute is access
and opportunity, not guaranteed election results. see Turner
v. McKeithen, 490 F.2d 191, 197 (5th Cir. 1973).

The scope and purpose of Section 2 are best examined in
light of the two most significant vote dilution cases, White v.
Register, 412 U.S. 755, 93 S.Ct. 2332, 37 L.Ed. 2d 314 (1973) and
City of Mobile v. Bolden, 446 U.S. 55, 100 S.Ct. 1490, 64 L.Ed.
2d. 47 (1981). The facts of Mobile, the case to which Congress
adversely reacted, and those of fihitg, which set the standard
that Congress wished to codify, provide the background necessary
to apply the amended statute. Comparisons of the record in
this case with the findings of the district courts in Ehite
and Mobile make it clear that Section 2 was never intended
to reach the circumstances of the case at bar.

In flhitg, the record showed that the counties in
which the Plaintiffs challenged the at-large system had the

following characteristics: 1) a history of official racial

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discrimination, which continued to touch the right of blacks
to register, vote and to participate; 2) a majority vote
requirement in party primaries; 3) a place rule which
reduced multimember elections to a head-to—head contest for
each position; 4) only 2 blacks elected to the Texas legis-
lature since Reconstruction; 5) a slating system; 6) a
white dominated organization which controlled the Democratic
party and which did not need or solicit black support;
7) a consistent use of racial campaign appeals by the Demo-
cratic party. The district court concluded and the Supreme
Court agreed that the net results of these factors was to
shut racial minorities out of the electoral process.

Likewise in Mobile, the plaintiffs attacked the at-large
method of electing the city commissioners, 428 F.Supp. 384
(S.D. Ala. 1977). The district court, applying the test used

in Zimmer v. McKeithen, 485 F.2d 1297 (5th Cir. 1973), found

 

that the electoral system there was marked by a majority vote
requirement in both the primary and general elections, numbered
posts, and no residency requirement. In addition, in a city
whose population was 35.4% black, no black person had ever been
elected to the Board of Commissioners because of acute racial
polarization in voting. The court found further that the city
officials had made no effort to bring blacks into the main-
stream of the social and cultural life by appointing them to

city boards and committees in anything more than token

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numbers. The plaintiffs also marshalled evidence of police
brutality towards blacks, mock lynchings and failure of
elected officials to take action in matters of vital concern
to black people. On appeal to the Fifth Circuit, the Court
noted that the plaintiffs had prevailed on each and every
Zimmer factor, 571 F.2d 238, 244 (5th Cir. 1978).

The record in the present case differs dramatically
from the pictures drawn in H2132 and Mobile. Multi-member
districts in North Carolina simply do not operate to exclude
blacks from the political process as they did in those cases.
The degree of success at the polls enjoyed by black North
Carolinians is sufficient in itself to distinguish this case
from flhitg and Mobile and to entirely discredit the plaintiffs'
theory that the present legislative districts deny blacks
equal access to the political process.

The legislative history explicitly states that Section
2 is aimed at jurisdictions, like those challenged in flhitg
and Mobile, in which "racial politics dominate the electoral
process." 8. Rep. No. 417, 97th Cong., 2d Sess. 33 (1982).
The evidence before this court will not support a finding
that considerations of race dominate politics in North Carolina.
On the contrary, the record shows that coalition shapes the
political landscape and that the process provides effective,

responsive representation for all citizens of the State.

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The Senate Report identifies several factors which may
be relevant to the court's analysis in a vote dilution case
brought pursuant to Section 2. The record unequivocally
establishes that the State has prevailed on nearly every factor.

A. History of official discrimination that touched

the right to vote.

The defendants have not attempted to prove that official
discrimination which prevented blacks from actively participating
in the democratic process did not in fact exist in North Carolina,
as it did in virtually every State in the Nation. What distin-
guishes North Carolina, however, is the aggressive affirmative
action taken by the State to remove all barriers and impediments
and to encourage political interest and activity by the black
community.

The drive to engage blacks in the electoral process in
this State began before the passage of the Voting Rights Act
in 1965. In Mecklenburg and Wake Counties, for example,
voter registration drives aimed particularly at increasing
black registration began before that date. Over the past
years the State Board of Elections has redoubled its efforts
to reach those groups in the State that are relatively under—
registered, especially blacks. The Board of Election's most

recent campaign included a comprehensive educational program

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to encourage interest in voting, and new legislation designed
to maximize access to registration. At the close of the
books prior to the 1982 General elections, the Board's drive
had resulted in a 17% increase in registration among blacks.
By the adjournment of the 1983 Session, the General Assembly
had enacted new legislation providing for more registrars,
more registration locations and generally easier access to
registration.

No barriers or impediments to registration and voting
presently exist in North Carolina. Moreover, the State has
affirmatively and effectively sought to eliminate any residual
effect of past discrimination which "touched the right to
vote." Based on the whole record, it cannot be concluded
that those past impediments to political participation have
any perceptible impact on the ability of black citizens to
involve themselves effectively in the democratic processes of
North Carolina today.

The Senate Report does not purport to cast in stone
the definitive inflexible list of relevant factors to be
considered in Section 2 cases. The factors are meant to be
exemplary of the types of evidence which might be relevant,
and the relevance of any given item may vary from case to
case. In this instance, this first factor is not particularly
relevant, largely because the State's effort to overcome the

effects of past electoral discrimination has been so successful.

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The mere existence of impediments to the exercise of the fran-
chise by minorities at some time in the past should not "in
the manner of original sin" continue to be accounted against
the State long after the barriers have been removed and the

residual consequences ameliorated.
B. The extent to which voting is racially polarized.

The plaintiffs' expert witness, Dr. Bernard Grofman,
testified that voting in the elections in this state is
severely and persistently racially polarized. GROFMAN T. 82.
Dr. Grofman's conclusion, however, is based on Dr. Grofman's
definition of racially polarized voting. His definition is
as follows:

Racially polarized voting occurs when the differ-

ence in voting patterns of black voters and white

voters are such that the racial composition of the

electorate will affect the election outcome, that

is, if the election were held entirely within the

members of one community as opposed to entirely

within the members of the other the set of candi-

dates elected would be different. GROFMAN T. 195.

Whatever merits Dr. Grofman's definition may have as a
theoretical construct, it has very little to offer to an analysis
of a real political contest where the objective of any candidate,
regardless of race, is to win. Grofman considers racial polari-
zation "substantially significant" when less than 50% of the

white voters vote for the black candidate. GROFMAN, T. 81.

In terms of political reality, this is a totally arbitrary

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distinction. Racially polarized voting is significant ("poli—
tically," "substantially," "statistically" or otherwise,) when
the black candidate does not receive enough white support to

win the election, whether that be 10% or 50% of the white vote.

A candidate is primarily concerned with receiving more
votes than his opponents, not with the color of the person
who votes for him. Discrete and different voting patterns
among racial groups concern the candidate when they operate
to prevent him from winning. This political reality and not
Dr. Grofman's academic niceties lie at the root of Congress'
inclusion of polarized voting in Section 2 analysis. The
Senate Report explicitly states that "[i]f plaintiffs assert
they are denied fair access to the political process in
part, because of the racial bloc voting context within which
the challenged election system works, they would have to
prove it." S. Rep. at 34 (emphasis added). The mere presence
of different voting patterns in the white and black electorate
does not prove anything one way or the other about vote
dilution. What is probative of vote dilution is voting along
racial lines which shuts the minority group out of the process
by consistently defeating the candidates of its choice.

Dr. Grofman was unable to cite any support in the
political science literature for his definition. More
importantly, his definition cannot be reconciled with the
legislative history of Section 2. The Senate Report speci-

fically endorses single-shot voting, therefore a prohibition

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on single-shot voting is evidence of vote dilution. Every time
black voters concentrate their votes on one black candidate

in an election for a multimember delegation, while the whites
generally cast all their votes, the voting will be polarized
according to the Grofman theory. A definition of polarized
voting which condemns single-shot voting is obviously both
overbroad and politically naive.

Another critical problem with Dr. Grofman's definition
is that it does not comport with the legal definition developed
in vote dilution cases. In Rogers v. Lodge, --- U.S. ---, 102
S.Ct. 3722 (1982) the Supreme Court described polarization
in terms of its capacity to effect actual election outcomes:

Voting along racial lines allows those elected to

ignore black interests without fear of political

consequences, and without bloc voting the minority
candidates would not lose elections solely because

of their race. 102 S.Ct. at 3731.

Racially polarized voting is probative of vote dilution only
insofar as it is outcome determinative. In other words,
where blacks consistently lgsg elections because no whites
or few whites will vote for them, the voting is racially
polarized. Where blacks gig because of single-shot voting
by blacks combined with substantial support from whites, the

voting is not racially polarized in any meaningful legal

sense .

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In NAACP v. Gadsden County School Board, 691 F.2d 978
(11th Cir. 1982), the court quoted the language from Rogers
as a guide to gaging polarized voting in Gadsden County
elections. The court found that black candidates had lost
elections solely because of their race. In a county in
which blacks comprised 48.5% of the registered voters and in
which 14 blacks had run for office since 1972, only 1 black
had been elected. Voting by whites along racial lines had
prevented blacks from winning elections.

Similarly, in McMillan v. Escambia County, Florida,
688 F.2d 960 (5th Cir. 1982) no black had ever served on the
County Commission elected at large. The Court of Appeals
noted that "it is sensible in this case as it was in Egggg to
expect that at least some blacks would be elected absent
racial polarized voting." 688 F.2d 960, 966 at n.l4. Here
again, the court viewed racial bloc voting as probative of
the issue of vote dilution insofar as it excluded blacks from
winning elections.

The statistical manipulations of the election data
performed by Dr. Grofman, while inherently limited, are in fact,
helpful in an analysis of racial polarization. Among the
elections reviewed by Grofman, the defendants contend that the

1982 election results are the most relevant to present case.

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Progress in North Carolina has been so rapid that patterns
which occurred even 4 or 5 years ago may not accurately
reflect current trends.

The 1982 election results do not reflect any signifi-
cant degree of polarized voting. Primary and general elections
in Durham, Forsyth, Mecklenburg and Wake counties produced
winning black candidates who received between 30% and 50% of
the white vote. At the same time, the successful white
candidates in these elections received only 40% to 60% of
the white vote. The salient point, however, is that blacks
E22 these elections with combined black and white support.
Voting along racial lines does not prevent blacks from
attaining elective office; therefore the degree of racial

polarization is not significant within the meaning of Rodgers
1/
v. Lodge.

 

1/ It is curious to note that Dr. Grofman found every
election in which a black was successful to be aber-
rational. GROFMAN T. 144. Obviously when a system,
rule or definition is either fraught with exceptions
or unduly complex because it must strain to reconcile
itself to the external reality it purports to explain,
the system or the definition needs to be reevaluated.
Dr. Grofman‘s sophisticated purely statistical analysis
has a whole grab—bag of elaborate nonquantifiable
appendages for explaining away white support for blacks
and black electoral success.

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C. The Majority Vote Requirement

Although North Carolina has a majority vote requirement
for primaries, this provision has no racial impact on election
to the General Assembly. Because the one-party nature of the
state greatly inflates the importance of victory in the
Democratic primary there is little support for eliminating
the majority vote requirement. In fact a bill introduced in
the General Assembly last session by Kenneth Spaulding, a
black Representative, merely would have reduced the require-
ment to 40%.

The plaintiffs' evidence regarding this factor is
deficient for the same reason their case must fail on the
issue of past discrimination in voting. Here again the
plaintiffs have mechanically proven the mere existence of a
factor listed in the Senate Report which in this case is
simply not relevant to the issue of vote dilution. A study
superimposing Representative Spaulding's proposal on all
legislative elections back to 1964 shows that no additional
blacks would have won as a result of a requirement reduced to
40%. Furthermore, the present majority requirement was not
invoked in the 1982 legislative primaries in any of the multi-
member districts which are being challenged. Thus, the majority
vote requirement as it operates in the elections for the North
Carolina legislature has no racial impact and is not relevant

to the issue of vote dilution under Section 2.

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D. The socio-economic effects of discrimination and political
part1c1pation.

This criterion from the Senate Report must be read
fully and in conjunction with its accompanying footnote 114.
The Report states that a court may examine "the extent to
which members of the minority group in the state or political
subdivision bear the effects of discrimination in such areas
as education, employment and health, which hinder their
ability to participate effectively in the political process."
8. Rep. at 29. (emphasis added.) Thus, a plaintiff may
properly introduce evidence, for example, of inferior health
care, education, and income among black citizens. The rele-
vance of this highly prejudicial evidence, however, is
contingent upon proof that the level of participation by
blacks in the political process is depressed.

Note 114 confirms this reading of Factor 5. There,
Congress expressed its intent that a plaintiff need not prove
a causal nexus between disparate socio—economic status and
depressed political activity. However, social and economic
circumstances have no relevancy at all to the issue of vote
dilution if participation by the group claiming dilution is
not in fact depressed. Note 114 does not relieve the plaintiffs
of proving depressed political participation, it merely relieves

them of proving the nexus between the two circumstances.

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The plaintiffs seem to have interpreted Factor 5 and
Note 114 to say that evidence of inferior economic and social
status is proof of depressed levels of participation in the
democratic process. The plaintiffs did indeed offer evidence
that blacks fared less well than whites on several socio-
economic measures. A witness offered as an expert in political
sociology then testified that the lower one's economic status
the less likely one is to participate in the political process.
LUEBKE T. 39g.

Nothing in the record, however, supports the finding
that participation by blacks in electoral process of North
Carolina is depressed. Rather, the whole record reflects
vigorous participation by blacks in every aspect of political
activity. First of all, nearly every one of the plaintiffs'
own witnesses recited a series of Democratic party offices,
elective offices and appointed political positions in which
they had served. The activities of just this small group of
people cast some doubts on any claim of either depressed
participation or unequal opportunity. The plaintiffs' own
witnesses also testified about successful volunteer efforts
by black leaders and civic groups to increase voter regi-

stration. This too is hardly reflective of a politically

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inactive black community. Furthermore, the power wielded by
such organizations as the Durham Committee on the Affairs

of Black People, the Mecklenburg Black Caucus, Raleigh-Wake
Citizens Association, the Black Women's Political Caucus and
the Wake County Democratic Black Caucus, evidence a vital
and sophisticated black organization. Since the plaintiffs
have failed to prove that political participation on the
part of the blacks in North Carolina is depressed or in any
way hindered, the evidence of disparate economic and social
status is not particularly relevant to the issue of whether
the challenged legislative districts dilute black voting

strength in violation of Section 2.
E. Racial appeals in political campaigns.

Plaintiffs introduced numerous articles, political
cartoons, and political advertisements in an attempt to show
that racial appeals have been used extensively in electoral
campaigns in North Carolina. Many of the exhibits were of
such age as to be admissible only under the "ancient documents"
exception to the rule against hearsay and consequently they
bear no reasonable relationship to the state of political
vaffairs in North Carolina today. Of the more recent advertise-
ments many were clearly non-racial and on others reasonable
minds could easily differ as to whether racial inferences of

any kind could be drawn from them.

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The plaintiffs' testimony on this topic, which came
from Dr. Paul Leubke, was simply not credible. Leubke insisted
that campaign slogans such as "Eddie Knox will serve all the
people of Charlotte" and "Knox can unify this city" were
racially motivated. He also maintained that pictures of
black candidates in political ads were always racial appeals.
Most damaging to his credibility, however, was Luebke's
position that what might be a racial appeal in the mind of
one person could never be fair political comment in the mind
of another.

The defendants showed that the practice of running
one's own picture or the picture of one's opponent in campaign
literature is common in North Carolina politics. It is also
common for all the candidates of one party who campaign
together before the general election to circulate advertise-
ments with pictures of each of the party primary winners.
Moreover, defendants have shown that "racial appeals" are
ineffective and counterproductive. Dr. Luebke insisted, for
example, that the white candidates for the Durham County
Board of Commissioners made racial appeals throughout their
campaign advertising in 1980. Luebke found the slogan "Vote
for Continued Progress" to be racially offensive. Nonetheless,

2 of the 5 seats in that election were won by blacks and the

_17-

Commissioners elected one of the blacks as chairman of the
County Board.

To the limited extent that Plaintiffs may have adduced
evidence of racial appeals in political ads, they have failed
to show that they are anything but aberrations, occurring
only in isolated instances and in association with a limited
number of campaigns. There is no evidence of any racial appeal
in any campaign for the General Assembly.

Nor is there any evidence that these racial appeals
have the supposed desired effect. On the record it appears
that the voters of North Carolina do not respond to this
campaign tactic and consequently even the rare truly racial
advertisement does not have the effect of limiting or decreasing
the opportunity for black citizens to be elected. Thus the
evidence on this factor adds little to the plaintiffs' claim
that the present districting denies blacks an equal opportunity

to register and vote and to elect candidates of their choice.

F. The Extent to Which Blacks Have Been Elected

Blacks have enjoyed great success in gaining public
office at all levels of government. In the most recent
elections for the General Assembly 12 blacks won seats in the
Senate and House of Representatives. Five of these legislators
were elected at—large in majority white multimember districts.
Two other black candidates, both running for their first

elective office, came within a hair's breadth of winning.

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At the local level, 202 city councilmen and town
commissioners are black, with 108 of these having been elected
at-large in municipalities with majority white voter registra-
tions. Nineteen black mayors are presently serving across
the state and six of them won election from majority white
constituencies. In addition, 30 of the 36 black county
commissioners in office were elected at-large in counties
with a white voting majority. Finally, all three blacks who
have run for statewide judicial offices have, in fact, been
elected.

This record of success in elections goes far towards
refuting the allegation that blacks lack access to the political
process. Not only do blacks consistently win elections across
the state, they frequently win with substantial white support
in at-large white majority districts. Just as the consistent
failure of blacks at the polls is a powerful indication of
exclusion from the process, consistent success strongly

suggests equal access and opportunity.
G. Responsiveness

The plaintiffs have not seriously disputed that the
elected members of the legislature are responsive to the
particularized needs of the black community. The record is

replete with examples of the sensitivity and accountability

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of elected officials to black members of their constituencies.
In its most recent session, the General Assembly greatly
increased the availability of voter registration. The budget
included an allocation for sickle cell anemia research, a
holiday honoring Dr. Martin Luther King was established, and
local legislation changing the method of election to the Wake
County School Board from a district system to an at-large
arrangement was proposed at the request of black leaders and
civic groups in Wake County.

In its discussion of polarized voting in Rodgers v.
nggg, --— U.S. ———, 102 S.Ct. 1335 (1982) the Supreme Court
noted that when a racial majority can win all the seats in an
at—large election without the support of the minority, it is
possible for those elected to ignore the views and needs of
the minority with impunity. When this occurs, the members
of the minority are essentially excluded from the democratic
process because they have no representative voice. It is
this very potential to shut blacks out of the process without
fear of political consequences which makes unresponsiveness
of elected officials one of the indicia of a Section 2 viola-
tion. In the present case blacks are not excluded from the
process by unresponsive white representatives. White candi—
dates need black support to win, and many black political

organizations regularly endorse white candidates. Consequently

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white office-holders are held accountable by the black community.
Under these circumstances, the responsiveness of the members of
the General Assembly to the black citizenry further evidences

the effective participation of blacks in the political processes

of North Carolina.

H. Legitimate State Policy Behind County-Based Representation

The plaintiffs adduced no convincing evidence that the
state policy of creating multimember districts to accommodate a
county-based reapportionment is tenuous. The defendants' evidence
showed that, much to the contrary, this policy has been consist-
ently applied since the 17th century. The continued viability of
counties today, especially as the administrative unit for the
delivery of most state services justifies the legislature's
desire to maintain whole counties in the formation of electoral
districts whenever possible. In addition, the General Assembly
every session enacts a large number of local bills. This unique
aspect of North Carolina government depends on unified county
representation which simply cannot be as well accomplished when
a county is divided among several districts or is internally
subdivided. The legitimacy of the state policy behind multimember
districts rebuts any inference of an intent to exclude blacks
from the political process.

The Senate Report states that the Committee did not intend
that these factors be used "as a mechanical point counting device."

S. Rep. at n.118. Rather, Section 2 requires the court to make

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a judgment, "based on the totality of circumstances and guided
by those relevant factors in the particular case." S. Rep. at
n.188. The statutory touchstone of this inquiry is whether
the system is open to full minority participation. Dove v. ,
M9953, 539 F.2d 1152 (8th Cir. 1976).

The plaintiffs' case rests not upon a denial of access
to the political system, but upon the contention that success
of black candidates is not guaranteed. The plaintiffs contend
that multimember districts discriminate against blacks because
blacks usually vote for blacks and less than a majority of
whites vote for blacks. The argument continues that if certain
urban areas were divided into single—member districts, blacks
would be guaranteed victory in a definite number of districts.
The relief requested obviously has nothing to do with providing
access to the political process. The plaintiffs have essentially
asked this court to remove black voters and candidates from
the competitive electoral arena and to protect them from the
vagaries of political fortune. Clearly, Section 2 does not

require this. In Whitcomb v. Chavis, 403 U.S. 153 (1971)

 

the court wrote:

As our system has it, one candidate wins, the
others lose. Arguably the losing candidates'
supporters are without representation since
the men they voted for have been defeated;
arguably they have been denied equal protec-
tion of the laws since they have no legisla-
tive voice of their own. This is true of

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both single-member and multimember districts.
But we have not yet deemed it a denial of
equal protection to deny legislative seats
to losing candidates, even in those so-called
"safe" districts where the same party wins
year after year.
This language is as applicable to Section 2 as it is to the

Fourteenth Amendment.

Conclusion

For the reasons stated herein the Defendants respect-
fully request the Court to deny the plaintiffs the relief
sought and to enter judgment in favor of the defendants.

RUFUS L. EDMISTEN
ATTORNEY GENERAL

WW”

Ja e Wallace, er
y Attorney G eral
for Legal Affairs

Attorney General's Office

N.C. Department of Justice
Post Office Box 629

Raleigh, North Carolina 27602
Telephone: (919) 733-3377

Norma Harrell

Tiare Smiley

Assistant Attorney General
Attorneys for Defendants

Of Counsel:

        

'5 Leonard, Esqu1re
een Heenan McGuan Esquire
Offices of Jerris Leonard, P.C.
900 Seventeenth Street, N.W.

Suite 1020

Washington, D.C. 20006

(202) 872—1095

 
   
 
 

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing

\

Defendants' Post—Trial Brief by placing a copy of same in the United

States Post Office, postage prepaid, addressed to:

Ms. Leslie Winner :
Chambers, Ferguson, Watt, Wallas, MX

Adkins & Fuller, P.A. -g; /V‘
951 South Independence Boulevard

Charlotte, North Carolinaa 28202

Ms. Lani Guinier
10 Columbus Circle
New York, New York 10019

Mr. Arthur J. Donaldson

Burke, Donaldson, Holshouser & Kenerly
Attorneys at Law

309 North Main Street

Salisbury, North Carolina 28144

Mr. Robert N. Hunter, Jr.
Attorney at Law

Post Office Box 3245

Greensboro, North Carolina 27402

Mr. Hamilton C. Horton, Jr.

Horton, Hendrick, and Kummer
Attorneys at Law

450 NCNB Plaza

Winston-Salem, North Carolina 27101

Mr. Wayne T. Elliot

Southeastern Legal Foundation
1800 Century Boulevard, Suite 950
Atlanta, Georgia 30345

This the 2 day of October, 1983.

 

J WALL CE, JRgfi