Norwood v. Harrison Appellants' Brief

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STIPULATIONS 

Based upon the record evidence before the Court, the parties agree that they will not 

contest in this case that: 

1. In North Carolina and in the areas comprising Congressional Districts 1 and 12 of 

the 1997 Sessions Laws, Chapter 11 in the 1997 Redistricting Plan, African-American voters are 

politically cohesive. 

2 In North Carolina and in the areas comprising Congressional Districts 1 and 12 of 

the 1997 Sessions Laws, Chapter 11, the white majority votes sufficiently as a bloc to enable it, in 

the absence of special circumstances, usually to defeat the African-American voter’s preferred 

candidate. 

3 North Carolina and the areas comprising Congressional Districts 1 and 12 of the 

1997 Sessions Laws, Chapter 11 the have a long history of official discrimination against its 

minority citizens which has affected the right of minority citizens to register, vote, and otherwise 

participate in the electoral process. 

4. For nine decades, from 1901 until 1992, no African-American candidate had been 

elected to Congress in North Carolina. 

S. In North Carolina, African-American voters were disenfranchised as a result of 

deliberate state laws that both denied African-American voters access to the ballot box and diluted 

their votes. 

0. The State of North Carolina utilized measures such as poll taxes, literacy tests, 

anti-single shot voting laws, and at-large and multi-member election districts to exclude African- 

Americans from the political process. 

2. In its 1970 and 1980 reapportionment plans, the North Carolina General Assembly 

intentionally fragmented the African-American vote in the northeastern portion of the State to 

make sure African-American voters could not garner enough support to elect their preferred 

candidate to Congress. 

8. In North Carolina, racial appeals in campaigns have been used, as late as the 

1990’s, by white candidates to discourage white voters from voting for African-American 

candidates. 

9. The minority citizens of the State of North Carolina and the areas comprising 

Congressional Districts 1 and 12 of the 1997 Sessions Laws, Chapter 11 continue to bear the 

effects of historical racial discrimination in such areas as education, employment, and health, 

which hinders their ability to participate effectively and equally with white citizens in the political 

process. 

 



  

10. African-American voters as a whole are less well-educated, lower-paid, more likely 

to be in poverty, and have less access to telephones, cars, and money than do their white 

counterparts, which adversely affects their ability to participate effectively in the political process. 

11, There 1s a strong basis in evidence for the State of North Carolina to have 

determined that it had denied minority voters an equal opportunity to participate in the political 

process and elect candidates of their choice to office. 

12. There is a strong basis in evidence for the State of North Carolina to have 

determined that it had a compelling interest in complying with the Voting Rights Act and in 

ensuring that racially polarized voting patterns and the lingering effects of the State’s past 

discrimination did not exclude the State’s African-American citizens from equal access to the 

political process.