NAACP v. NAACP LDF Memorandum of Law in Support of Defendant's Motion for Summary Judgment

    INDEX

Accordian Fi-1e #L- PLEADINGS

File #l-Supreme Court Briefs

Contents- Escambia County v. Henry McMillan Brief of Appellants

, Canady v. Lumberton City Board of Education

Perkins v. Matthews Briefs of Counsel

File *2' 5th Circuit Pleadings and Briefs

Contents - Lance v. Plummer Brief for Appellees

Thomasville Branch of the NAACP v. Thomas County Ivlemo and Order

File #3- 6th Circuit Pleadings and Briefs

Contents- Buchanan v. The City of Jackson and the State of Tennessee
Plaintiffs Supplemental Brief on Appea

File #4- 7th Circuit Pleadings and Briefs

Contents- Ketchum v. Byrne Brief for the Lawyers Committee for Civil
Rights undffi Curiae

File #5-11-th Circuit Pleadings and Briefs

Contents-U.S. v. Marengo County Appellants Brief

File #6- Alabama Pleadings

Contents -Brorvn v. Board of Schoo1 Commissioners Plaintiffs Proposed Findings
of Fact a

U.S. v. Conecuh Defendnats Answer

U.s. v. Conecuh Defendants Interrogatories and

U.S. v. Conecuh Application Of the U.S. for a
Order

U.S. v. Conecuh Court Room Proceedings

U.S. v. Conecuh List of suggested PolI Workers

U.S. v. Conecuh Summons

U';S. v. Conecuh ComPlaint

U.S. v. Conecuh Order

Bolden v. U.S. Order

Bolden v. City of Mobile Alabama Order

File #7- Arkansas Pleadings \

Contents-- PhillipsCounty Ivlinisterial Alliance v. Cooper Complaint

FiIe *8- Connecticut Pleadings

Contents-Greater New Haven Coalition for People v. Registrar Plajntiffs

R.equest for Production

Temporary Restraining

-1-

/



INDEX

FiIe #9- District of Columbia Pleadings

Contents-County Council of Sumpter County v. U.S. Amended Memo

Countv Council of Sumpter County v. U.S. memo

County Council of Sumpter County v. U.S. Post-Trial Brief

State of South Carolina v. U.S. Mgmo and Order

Busbee v. Smith Findings of Fact and Conclusions of Law

South Carolina v. NAACP Memo and Order

File#10- Georgia Pleadings

Contents-Fourth Street Baptist Church .v Board of Registrars Complaint

Four Plaintiffsr
Response s

File#11- Indiana Pleadings

Contents- Project Vote v. Orr Temporary Restraining Order

Accordian File #2- PLEADINGS (con. )

I'iIe #L2- Illinois Pleadings

Contents-Ketchum v. City Council of Chicago Post -Trial Brief

File #13-

Contents-

File #14-

Contents-

Ketchum v. Byrne Complaint in Intervention

Ketchum v. Byrne Memo of Law

Ketchum v. Byrne Application of the U.S. to Intervene

Louisiana Pleadings

Ivlajor v. Treen Post-TriaI Memo

Major v. Treen Plaintiffs Trial l{emo

Mississippi Pleadings

Jackson v. Winter Complaint

Jordan v. Winter Memo

Flle #15- North Carolina Pleadings

Contents- Ci@ Post-Trial Iv1emo

Ginqles v. Edmisten Appendix to

Ginqles v. Edmisten Plaintiffs
and Conclusions of Law

Post-Trial l"lemo

Proposed Findings of Fact

Johnson v. Halifax Motion

Johnson .v Halifax Motion

Johnson v. Halifax Memo in Support

for Preliminary Injunction

for fnterim Relief

-2-



INDEX

File #15- (con. )

Johnson v. Halifax Affidavits

File #16- Pennsylvanj.a Pleadings

Contents-Project Vote v. Thornburgh Preliminary Injunction

File *17- South Carolina Pleadings

Contents-Simkins v. Columbia Plaintiffs Answers to Interrogatories

Temporary Restraining OrderSimkins v. Columbia Motion for

Simkins v. Col_grnbie Complaint

Accordian File #3- COURT OPINIONS

File #18-Supreme Court Opinions

Contents-Port Arttrur v. U.S.

Clifford v. Seaman

Gaffney v. Cummj-nqs

Palmer v. Ihompson

Fullilove v. Klutznick

Fitzpatrick v. Bitzer

Hathorn v. Lovorn

Whj-te v, Regester

Rogers v. Lodge

Smith v. Allwright

U.S. v. Classic

Grigqs v. Duke Power Co.

Oregon v. Mitchell

Albermarle v. Moody,

Gatson 9ountv v. U.S.

McCain and Spencer v. Lybrand

Sumter County School District v. Edge

Katzenbach v. Morqan

-3-



INDEX

File #19- 5th Circuit Opinions

Contents-Kirksey v. City of Jackson Mississippi

Lodqe v. Buxton

Nevett v. Sides

Robinson v. Commissioners CourtrAnderson County

Searcy v. WiIliams

Velasquez v. City of Abilene

Zimmer v. McKeithen

File #20- 7th Circuit Opinions

Contents-Ketchum v. Byrner,Errrd, Revised Opinion

File#2l- Llth Circuit Opinions

Contents- Brown v. School,Commissioners of Mobile CountyrAla

U.S. v. Marengo

Accordian File #4- Court Opinions (con'd)

File #22- Alabama Opinions

Contents- Bolden v. City of Mobile, AIa

Brown v. Board gf School Commissioners

Burton v. Hobbie

Buskey v. Oliver

Underwood v. Hunter

Whitfield v. Oliver

File *23- Distrj-ct of Columbia Opinions

Contents- Mississippi v. Smith

File #24-, Georgia Opinions

Contents-U.S. v. The State of Georgia

File #25-Illinois opinions

Contents- Chester v. Rybiki

In re: Illinois Congressional Districts Reapportj-onment Cases

File #26- Louisiana Opinions

Contents-Major v. Treen

-4-



INDEX

File *27- Mississippi Opinions

Contents- Carter v. Luke

Jordan v. Greenwood

ilordan v. Wintcr'

Kirksey v. Board of Sup'rs Of Hinds County, Miss.

Lavorn v. Hathorn

Lucas v. Bolivar County, Miss.

File#28- New York Opinions

Contents- Herron v. Koch

Phillips v. Rockefeller

File #29- North Carolina Opinions

Contents- Gingles v. Edmisten

File #30- Texas OPinions

Contents- Political Civil Voters Organization and J.R. v. City of Terrell

File #31- Virginia Opinions

Contents- CoI

Accordian #5- Recent Voter Registration Cases

File #32- Model Pleadings

Contents- Model Complaint and Questionaire

Fite*33- Coalition for Sensible Solutions v. Wamser

Contents- Defendants propsed findings of fact and conclusions of law

Defendants Post-Trial Memo

Memorandum Opinion

File *34- HARRIS v. GRADDICK

Contents- Complaint

Memo Opinion

Order

File #35- Push v. A1lain

Contents- Complaint

-5-



INDEX

File #36-V.E.P. v. CleIand

Contents- Complaint

Motion for Preliminary Injunction

Order

States Draft Regulations

Plaintiffs' Proposed Regulations

Accordian File #6- Access Issues and Affidavits

Access Issues Contents- Jack Novick's Draft Demand Letter

Jack Novick' s Correspondence

DetroitElection Commission Volunteer Deputy
Registrar Voter Registration Program Rules and Regulations

Project Vote Summary-De1aware Voter Registration laws

Fed. Constitutional Law and American Local
Government: A Treatise for City Attorneyr s, Public Interest Litigators
and Students.

Draft Letter: Seeking Interpretation of Federal
Statute to Permit Access to CAP facilities for Registration Purposes.

Governor of Penn. Ivlamagement Directive

Access to Registration and Voting Continuing
Obstacles

Affidavits Contents-Model Questionnaire Concernj-ng Efforts to Obtain
Appointment Of Deputy Registrars

V.E.P. v. Cleland Affidavits

Push v. AIlain Affidavits

Accordian #7- ARTICLES PAIvIPHLETS AND PUBLICATIONS , ATTORNEYS NOTES

Contents, Articles, Pamphlets, and Publications

Barriers to Participation: Rules of the Gamer €tfl Overview, BY William
Robinson, executive Director, Lawyers Committee for Civil Rights Under Law

Fulfilling the Promise of Disclosure, By Project on Investj-gative Reporting
on Money in Politics

Can Foundations Support Voter Registration? By Thomas A. Troyer, and Boisture

Anybody Object to A Little More Democracy? By William Poe

The Presidential Election Process: A selected List of References

Eradicating Racial Discrimination in Voter Registration: Rights and
Rernedies Under the Voting Rights Act Amendments of 1982

HaIf a Foot _n The Door, By Dr. Brian Sherman

-6-



INDEX

Articles, Pamphlets, and Publications Contents (con'd)

Pamphlet on the National Ivleeting of the E-ergency Mobilization of the
Right to Vote

Pamphlet on Registering and Voting By the NAACP-LDI'

Civil Rights, Social Justice, and Black America, By The Ford Foundation

Democracy in America: Towards Greater Participation, By the New Wor1d
Foundation

Voter Registration and the States: Issues Problems and Choices, Conference
on Alternative State and Local Policies

Report on the Effects of the Reagan Administation on the Voting Rights Act,
By Laughlin lt{cDonald

Barriers to Effective Participation in Electorsl Poilitics

Getting Rid of Registration Roadblocks, Armand Derfner

Voter Registration and the Fj-rst Amendment, By Lucas Guttentag

DuaI Registratj-on and Other Barriers to Registration, Jane Spencer

The Identification and Evaluation of Racial Gerrymandering, John O'Loughlin

Pamphlet, Making Their Votes Count , by The NAACP-LDF

LDF Annual Report,L9SL-82

Obstacles to Voter Registration to be Challenged By Litigation Campaign

Paul Moore Jr. Pamphlet

Blacks and the Ballot 1944-L984, by the LDF

Toward a Class based Realignment of American Politics: A Movement
Strategy, By Richard Cloward and Frances Fox Piven

NAACP -LDF L982-3 Annual Report

LDF News

The News Media and the Democratic Process, by Michael Schudson

L982 Kentucky Directory of Black Elected Officials
Democracy Who's For It, Christianity and Crisis
Human Servj-ces Employees Regj-stration , Voting and Education Campaign

Southern Chhnges, Southern Regional Council

Quarterly Alert, Joint Center for Politica1 Studies Corporate Association
Program

Run-Off Primaries-- OnIy a Piece of the Iceberg

State Report on Election Law Reform

Human Serve Pamphlet

-7-



INDEX

Articles ,Pamphlets, and Publications Contents (con'd)

Alternative Ways for Government Human Service Agencies and Personnel toparticipate in Voter Registration

Aygust L984 Issue of FOCUS, Joint Center for Political Studies

ATTORNEYI S NOTES

Contents- Steering Committee Notes

Steering Committee Sign - Up Sheets

Accordian #9- Executiyg Ordersrleqislation, l,egislative Testimony
It{emos, Statistics, Studies

Executive Orders Contents

Columbus, Olio

Minnesota

New Mexico

New York

New Jersey

Legislation Content.s - Sg,t a.dd i*ian( +0 Ta/*{'

H. R. 6L47

Swift Hawkins Bill on Registration

H. R. 5762

Summary on Hearings on S.117'l ,5.L975,S.l-l-99, S. 2445, 5.2457, S. 2574

S. 3420, H.R. L2016, and H.R. 6088

Leqistative Testimony conrents <<-t hJ4ilN nf f$ t,!"t(F
Testimony of Arthur Eisenberg Before the Joint Senate and Assembly
Committees on Elections Submitted on Behalf of the New York Civil Liberti-es
Union, March L2, 1984

Testimony of Lani Guinier, NAACP-LDF. Subcommittee on Civil and Constitutional
Rights U.S. House of Representatives. July 26, 1984.

Memos Contents

l,Iemo To: Lani Guinier From Gay Crosthwaitr r€: State Responsibility

Memo b1a the National Emergency Mobilization on the Right to Vote

Memo To: Dan Hazen, Human Serve From : Gay Crosthwait, re:Lega1 Strategies
and Remedies Workshop at the Natj-ona1 Emergency Mobilization on the Right
to Vote

-8-



fNDEX

Press Release on the National Emergency Mobilization

Right to Register Campaign: Some Background Information

Statement of Lani Guinier ( Press Release)

Memo to: Art Ej-senberg From: Richard Bardenstein re: Standing

Impediments to Voter Registration: Specific Cases

Memo to: Penda Hair From: Mark Kende re: Standards for Leave of the Court
to Amend a Complaint in the 11th Circuit
Legal Theories for Registration Challenges (Attorney Work Product)

Memo from: Bert Neuborne To: Voter RegJ-stration Lawyers re: St. Louis
decision

Memo to: Jerry and Steve From Gwen re: Voter Registration Assn Meeting

Status Report on Voter Registration Litigation

LDF Press Release April 15, L9B2

It{emoto: Richard Cloward From:Arthur Eisenberg Re: The Fi-rst Amendment
Right to Engage in Voter Registration Activity Within the Public Areas
of Governmental Offices

It{emo to:Lani Guinier From : Eric Schnapper .-: Registration Time/p1ace
Litigation

Memo to: Lani Guinier from: Eric Schnapper Re" Votj-ng Cases

Memo to:LDF Voter Registration Lawyers from: Eric Scnapper re: Survey
of State Voter Registration Problems

Memoto: Dennis Gardner and David Katsky from: Napolean B. WilliamsrJr.
re:Voting Rights Challenges

Memo to: Lani Guinier from: Jerry Salama re: Standing to sue in the
Mississippi Dual Registration Requirement Lawsuit

Memo to : Lani Guinier From: Steve Lapidus re: Standing to Attack Voter
Registration Laws

Memo to: Lamond Godwin from: Lani Guinier, Armand Derfner re: Enforcement
of Voting Rights: Registration Barriers

Memo to: State Organizers from: Nati-onal Headquarters re: Barriers in
Access to Public Agency Waiting Rooms, and to Deputization 

I

Project vote summary: Deraware voter Registration Laws /+ !lo.l' S^-''t't''-t ) t'{
)l i,,,. r,A\i/"1

Campaigns to Overturn Obstacles to Low Tncome/ t'linority Registration

Summary of Selected State Laws on Registration/-,;}Sl.trc 
.j""''{'In'I';'t t a"\{)

Voter Registration Network Background of Mass. Voter Registration/--r--/r/,,'7, ii.t.,i

Memo: to Hays Fellows and Directors From: Alice Brown re: The Voting '""'l -"'' "
Rights Act, Majority Vote Requirements and Litigation Strategies

-9-



INDEX

Memo to: Lani Guinier from: Mary F. Berry

Presidents Ford and Carter Head the List of Participants in Symposium
on American Voter Participation co-Sponsered By Harvard and ABC Inc.

Memo from: Planning Committee to: Leadership of Voter Registration Groups
and Civil Rights,Citizen Actj-on and SociaI Justice Organizations and
Other Interested Individuals re: Attached Draft Statement On Voter Registration
Barri-ers

Memo -Enforcemnet of Voting Rights : Registration Barriers

Press Release on JuIius Chambers takeover as LDF Director-Counsel

Memo- Continued Need for the Protections of the Voting Rights Act
And Section Fi-ve

Statistics Contents

The Non-Voters in 1980- 24 States Where They Could Have Made a Difference

Voting Statistics by State

Voting and Registration in the Election of L982

Congressional Districts in which Blacks Comprise MOre than 20* or More of
the Voting Age Population

The Effect of Voter Registration Laws on Black Voter Registration in 13
Southern and Border States

The Census, Statistics, and Voting Rightsrby Gordon Henderson

Census Information Kit

Statistics for Eric Schnapper

Doing a Racial Bloc Voting Analysis, b- Jim Lgewen
5ln q (a { ,\'5 Lr.^,.,., 'rl t'5l { i-r- r.'( n(( ll'd" 'r rut' \ ' ' ,
Studies Contents

The Causes and Consequences of Racial Socio-Economic Disparities in the
City of Jackson, Mississippi. By Chandler Davidson

Barriers to Black Voting: Examination of Socioeconomic Characteristics
and PoIiticaI participation. By !{iIliam P. O'Hare

An Analysis of Voting Behavior in Elections for the Mississippi Second
Congressional District in 1982

Accordian #9- Individual State fnformation

Contents-Florida

Memo to: Clyde Murphy, Peter Sherwood From: Eric Scnapper re: Florida

H. B. 49L

Georgia

HB 934/AP

Loui-siana

Voter Registration in Louisiana's Seven Largest Parishes

- 10-



INDEX

Iriissouri (contents)

Registration Staistics of Missouri by County

lttichigan (contents)

Attorneyr s Notes

llississippi ( contents )

Memo to: Lani Guinier From: Steve Lapidus res The Right to Vote in
Mississippi

New York (contents)

Clark v. Cuomo_ Record on Appeal

New York State Statistics (1980)

New York Census Data

North Carolina (contents)

Statistics by Race and Age

South Carolina(Contents) !

Statistics by County

Voter Registration Policies South Carolina Counties

Strom Thurmonds Roots

Tennessee (contents)

Registered Voters by County

Wilson County Statistics by District and Precinct

Virginia (contents)

1984 Voter Registration Schedule

Strengthening the Right to Vote in Virginia

Attorneyt s Notes

Virginia Election Laws

Virginiar s Voter Registration Laws: A Comparative Analysis

l,lemo to: The Honorable Charles S. Robb Governor of Virginia, from:
the Governorr s Commission to Increase Voter Registration

-+ 1-



ADDITIONS TO INDEX

Bills- Accordian #8

Contents- H.R. 5762

H. R. 6L47

Congressional Reports- Accordian#8

Contents- Draft Report on Registration Barriers by Stuart fshimaru

Conyers Report

Leqislative Testimonv- Acoordian #8

Contents- Testimony of Artur Eisenberg Before the Joint senate and
Assembly Committees on Elections submitted on behalf of
the New York Civil Liberties Union, Ivlarch L2, 1984.

Testirnony of Lani Guinier, NAACP-LDF. Subcommittee on
- Civil and Constitutional Rights, U.S. House of Representatives.

JuIy 26, 1984.

Summarv of Leqislative Testimony- Accordian *8

Contents- Summary of Hearings on S.LL77, S.1975, S.L199, 5.2445,
9.2457, 5.2574, S.3420, H.R. 1,20L6, H.R. 5088