Plaintiffs' First Request for Admission

    IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF LOUISIANA 

RONALD CHISOM, et al., 

Plaintiffs-Appellants, Civil Action 
v. No. 86-5075 

Section A 
EDWIN EDWARDS, et al., 

Defendants-Appellees. 

PLAINTIFFS' FIRST REQUEST FOR ADMISSION 

Plaintiffs, by their attorneys, request that defendants 

pursuant to Rule 36, Fed. R. Civ. P., and within 15 days after 

service of this request admit the truth of the following facts 

for purposes of this action and subject to all pertinent 

objections to admissability which may be interposed at trial. 

Pursuant to Rule 36, all written answers shall be addressed 

to the matter. Any answer shall be deemed inadequate which 

merely states with regard to any facts set forth herein that 

they are matters of public record and speak for themselves or 

which states that any facts set forth have previously been 

litigated. If any objection is made to any of the facts or 

documents set forth herein, the specific reasons for each such 

objection shall be stated fully in writing. Each answer to each 

of the facts and documents set forth shall specifically admit the 

matter, deny the matter, or set forth in detail why the answering 

party cannot truthfully admit or deny the matter. 



If defendants qualify their answer or deny only a part of 

•the matter of which an admission is requested, defendant shall 

specify which part of the request is true and qualify or deny the 

remainder. If defendants plead lack of information or knowledge 

as a reason for their failure to admit or deny, they must state 

in detail that they have made reasonable inquiry and state 

specifically what inquiries have been made to ascertain the 

requested information or the genuineness of-each document. If 

any facts stated herein are deemed by the defendants to be 

incorrect in whole or in part, defendants are requested to supply 

the correct facts to which each such request refers. 

These requests shall be deemed continuing and defendants 

shall be under a continuing duty to supplement the responses as 

required by Rule 26(e), Fed. It: Civ. P. 

1. Justices for the Louisiana state Supreme Court are 

elected from six Supreme Court Districts. 

2. Five of the districts elect one justice each. 

3. One district--the First Supreme Court District--elects 

two justices. 

4. Pursuant to La. Rev. Stat. § 13:101, the First Supreme 

Court consists of the parishes of Orleans, St. Bernard, 

Plaquemines, and Jefferson. 

5. The two judicial seats assigned to the First Supreme 

Court District are not filled in the same election year. 

6. One of the seats assigned to the First Supreme Court 

District is scheduled to be filled by election in the fall of 

1988. 



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7. One of the seats assigned to the First Supreme Court 

District is scheduled to be filled by election in the fall of 

1990. 

8. The First Supreme Court District is the only 

multimember Supreme Court District. 

9. The First Supreme Court District is the largest Supreme 

Court District in population. 

10. Elections for the Louisiana Supreme Court are covered 

by Louisiana's majority-vote requirement. 

11. In the twentieth century, no black person has sought 

election to the Louisiana Supreme Court from the First Supreme 

Court District. 

12. According to the 1980 Census, the combined total 

populations of Jefferson, Orleans, Plaquemines, and St. Bernard 

Parishes was 1,102,253. Of this total, 379,101 persons (34.4 

percent) were black. 

13. Louisiana has a history of official discrimination 

touching upon the right to vote and otherwise participate in the 

political process. 

14. Louisiana is covered by section 5 of the Voting Rights 

Act of 1965, 42 U.S.C. § 1973c, because it used a literacy test 

and has had a history of depressed political participation. 

15. In 1923, Louisiana authorized the use of a white-only 

primary. The use of white primaries continued until it was 

struck down by the U.S. Supreme Court in 1944. 

16. Louisiana established a majority-vote requirement for 

election to party committees in 1959 to diminish the political 



power of black voters. 

17. Voting in elections involving black candidates for 

political office the First Supreme Court District Parish is 

racially polarized in that such elections reflect a correlation 

between the race of voters and the selection of certain 

candidates. 

18. Voting in judicial elections involving black candidates 

in Orleans Parish is racially polarized in that such elections 

reflect a correlation between the race of voters and the 

selection of certain candidates. 

19. The demographic character of the New Orleans 

metropolitan area means that a district that includes both the 

city and suburban parishes submerges the city's predominantly 

black electorate within a larger group of white voters. 

20. The black community forms only one-third of the 

electorate in a four-parish race in the First Supreme Court 

District. 

21. White voters within the First Supreme Court District 

generally do not support black candidates in elections involving 

both black and white candidates. 

22. Louisiana enforced a policy of racial segregation in 

public education, transportation, and accommodations until these 

practices were outlawed by the Supreme Court and Congress. 

23. Louisiana operated a dual university system until 1981. 

24. According to the 1980 Census, in Orleans Parish, 70.8 

percent of white persons age 25 and over were high school 

graduates. 



25. According to the 1980 Census, in Orleans Parish, 46.9 

percent of black persons age 25 and over were high school 

graduates. 

26. According to the 1980 Census, in Orleans Parish, 11.16 

percent of white residents age 25 and over had completed fewer 

than eight years of school. 

27. According to the 1980 Census, in Orleans Parish, 21.78 

percent of black residents age 25 and over had completed fewer 

than eight years of school. 

28. According to the 1980 Census, per capita income for 

white residents of Orleans Parish was $9,781. 

29. According to the 1980 Census, per capita income for 

black residents of Orleans Parish was $3,985. 

30. According to the 1980 Census, the median household 

income for white households in Orleans Parish was $15,605. 

31. According to the 1980 Census, the mean household 

income for white households in Orleans Parish was $21,975. 

32. According to the 1980 Census, the median household 

income for black households in Orleans Parish was $8,847. 

33. According to the 1980 Census, the mean household 

income for black households in Orleans Parish was $12,159. 

34. According to the 1980 Census, the median family income 

for white families in Orleans Parish was $21,544. 

35. According to the 1980 Census, the mean family income 

for white families in Orleans Parish was $28,496. 

36. According to the 1980 Census, the median family income 

for black families in Orleans Parish was $10,516. 



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37. According to the 1980 Census, the mean family income 

for black families in Orleans Parish was $13,727. 

38. According to the 1980 Census, 7.4 percent of white 

families in Orleans Parish had incomes in 1979 below the poverty 

level. 

39. According to the 1980 Census, 11.5 percent of white 

persons in Orleans Parish had incomes in 1979 below the poverty 

level. 

40. According to the 1980 Census, 8.0 percent of white 

persons in Orleans Parish had incomes in 1979 that were below 75 

percent of the poverty level. 

41. According to the 1980 Census, 33.4 percent of black 

families in Orleans Parish had incomes in 1979 below the poverty 

level. 

42. According to the 1980 Census, 37.3 percent of black 

persons in Orleans Parish had incomes in 1979 below the poverty 

level. 

43. According to the 1980 Census, 29.1 percent of black 

persons in Orleans Parish had incomes in 1979 that were below 75 

percent of the poverty level. 

44. According to the 1980 Census, 6.76 percent of white-

occupied housing units in Orleans Parish had no telephone. 

45. According to the 1980 Census, 20.78 percent of white-

occupied housing units in Orleans Parish had no vehicle 

available. 

46. According to the 1980 Census, 14.22 percent of black-

occupied housing units in Orleans Parish had no telephone. 



47. According to the 1980 Census, 42.39 percent of black-

occupied housing units in Orleans Parish had no vehicle 

available. 

pectfully submitted, 

WILLIAM P. QUIGLEY 
631 St. Charles Avenue 
New Orleans, LA 70130 
(504) 524-0016 

ROY RODNEY 
643 Camp Street 
New Orleans, LA 70130 
(504) 586-1200• 

JULIUS L. CHAMBERS 
CHARLES STEPHEN RALSTON 
C. LANI GUINIER 
PAMELA S. KARLAN 

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

RON WILSON 
Richards Building, Suite 310 
837 Gravier Street 
New Orleans, LA 70112 
(504) 525-4361 

Counsel for Plaintiffs-
Appellants 

ci 



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CERTIFICATE OF SERVICE 

I hereby certify that on this ay of October 1988, I 

served a copy of the foregoing Plaintiffs' First Request for 

Admissions by sending a copy, by overnight delivery service, to 

the following persons: 

William J. Guste, Jr. 
Attorney General 
Louisiana Department of Justice 
234 Loyola Avenue, 7th Floor 
New Orleans, LA 70112 

M. Truman Woodward, Jr. 
909 Poydras Street, Suite 2300 
New Orleans, LA 70130 

Blake G. Arata 
201 St. Charles Avenue 
New Orleans, LA 70130 

George Strickler, Jr. 
639 Loyola Street 
Suite 1075 
New Orleans, LA 70113 

A. R. Christovich 
1900 American Bank Bldg. 
New Orleans, LA 70130 

Moise W. Dennery 
601 Poydras Street 
New Orleans, LA 70130 

Robert G. Puch 
330 Marshall Street, Suite 1200 
Shreveport, LA 71101 

I further certify that a copy of the foregoing document was 

served by first-class mail, postage prepaid, on counsel for 



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plaintiff-intervenor, addressed as follows: 

Robert S. Berman 
Attorney, Voting Section 
Civil Rights Division 
Department of Justice 
P. 0. Box 66128 
Washington, D.C. 0035-6128 

rney for Plaintiffs