St. Peter v Marsh Reply Brief in Opposition
Public Court Documents
October 1, 1981

12 pages
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Case Files, Cromartie Hardbacks. Plaintiffs’ Response to Defendants’ and Defendant-Intervenors’ First Request for Production of Documents, 1998. 9eb0baf6-d90e-f011-9989-7c1e5267c7b6. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/1ba51415-4495-4fff-8702-6d711dbdc512/plaintiffs-response-to-defendants-and-defendant-intervenors-first-request-for-production-of-documents. Accessed August 19, 2025.
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ww ww UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION Civil Action No. 4-96-CV-104-BO(3) MARTIN CROMARTIE, et al., Plaintiffs, V. JAMES B. HUNT, JR. in his official capacity as Governor of the State of North Carolina, et al , PLAINTIFFS’ RESPONSE TO DEFENDANTS’ AND DEFENDANT- INTERVENORS’ FIRST REQUEST FOR Defendants, PRODUCTION OF DOCUMENTS and ALFRED SMALLWOOD, et al, Defendant-Intervenors. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) PLAINTIFFS, MARTIN CROMARTIE, THOMAS CHANDLER MUSE, LOIS WEAVER, JOEL K. BOURNE, R.O. EVERETT, J.H FROELICH, JAMES RONALD LINVILLE respond to Defendants’ and Defendant-Intervenors’ First Request for Production of Documents through their counsel as follows: 1. Produce copies of all prepared testimony, photo-offset conference proceedings, affidavits and reports prepared by your experts in connection with other voting rights proceedings. ” w RESPONSE: Plaintiffs object that this request is overly broad and burdensome, as Dr. Weber has testified in over 40 such proceedings. However, in response to this request, we are providing his expert reports from the Shaw cases he participated in. 2. Produce copies of deposition or trial testimony by your experts given in connection with other voting rights proceedings. RESPONSE: Plaintiffs object that this request is overly broad and burdensome, as Dr. Weber has testified in many such proceedings. However, in response to this request, we are providing all his depositions and all trial testimony he has been able to locate from the Shaw cases he participated in. S. Produce each document identified or relied on in response to Defendants’ And Defendant-Intervenors’ First Set of Interrogatories (including all maps). As to any map required to be produced, please produce all supporting data and documentation or related writings, including electronic communications. RESPONSE: The documents identified or relied on in response to Defendants’ And Defendant-Intervenors’ First Set of Interrogatories are found in the VRA Section 5 Submission to the Justice Department or other documents already in your possession. - ww 4, Produce any and all alternative congressional districting maps of which you are aware and which you believe would have met constitutional and Voting Rights Acts requirements if they had been adopted by the General Assembly in 1997. Please produce such maps, including all supporting data and documentation or related writings, regardless of whether they were in existence in 1997 or whether the General Assembly had them before it. RESPONSE: In response to this request for production, plaintiffs offer the following list of plans which consist of all the plans we are aware of which meet or approach the constitutional requirements of Shaw v. Reno and related cases. Several of them may not fully satisfy the equipopulous requirement. These plans are all found in the VRA Section 5 Submission to the U.S. Department of Justice for the 1997 Congressional Plan: . 1996 Whole County Adjusted . 1996 Whole County Cong Plan 2 . 1996 Whole County Cong Plan 3 . Charlotte Observer 1996 Plan . Cong. District Executive Plan . Lee Plan-Congressional In addition, plaintiffs incorporate by reference the materials produced in response to Request #8, and the statements of Interrogatory answer #1. . - 5, Produce any and all alternative maps of one or more congressional districts, but fewer than all districts, of which you are aware and which you believe would have met constitutional and Voting Rights Acts requirements if they had been adopted by the General Assembly in 1997. Please produce such maps regardless of whether they were in existence in 1997 or whether the General Assembly had them before it. RESPONSE: We are not aware of any such maps which meet constitutional and Voting Rights Acts requirements, either published in the 1997 and 1998 VRA Submissions, or found anywhere else. 6. Produce any writings or electronic communications that reflect the terms, conduct, and results of any contests involving the drawing of maps for one or more congressional districts. RESPONSE: Plaintiffs’ response to this request for production is attached. 7. Produce copies of any and all congressional districting maps, including all supporting data and documentation or related writings, whether for one or more districts or all twelve, that were created, produced, or provided in connection with any contests involving the drawing of maps for one or more congressional districts. ® » RESPONSE: The copies of the maps and supporting data and documentation from the ADCR contest were turned over to the General Assembly in 1997. Several of the districts drawn in the ADCR contest can be found in the 1997 VRA Section 5 Submission to the U.S. Justice Department. 8. Produce any maps, including all supporting data and documentation or related writings, that were created or provided to plaintiffs and their counsel by any civic organizations, such as the League of Women Voters. RESPONSE: Plaintiffs’ response to this request for production is attached. This the 4th day of October, 1999 Ted NE Robinson O. Everett Everett & Everett N.C. State Bar No.: 1385 Attorney for the Plaintiffs P.O. Box 586 Durham, NC 27702 Telephone: (919)-682-5691 ® " Williams, Boger, Grady, Davis & Tuttle, P — by: /" Martin B. McGee State Bar No.: 22198 Attorneys for the Plaintiffs P.O. Box 2 Kannapolis, NC 28081 Telephone: (704)-932-3157 Douglas E. Markham Texas State Bar No. 12986975 Attorney for the Plaintiffs 333 Clay Suite 4510 Post Office Box 130923 Houston, TX 77219-0923 Telephone: (713) 655-8700 Facsimile: (713) 655-8701 ww Nh CERTIFICATE OF SERVICE I certify that I have this day hand delivered the foregoing Plaintiffs’ Response to Defendant- and Defendant Intervenors’ First Request for Production of Documents served to the following address: Ms. Tiare B. Smiley, Esq. Special Deputy Attorney General North Carolina Department of Justice 114 W. Edenton St., Rm 337 P.O. Box 629 Raleigh, NC 27602 Phone # (919) 716-6900 This the 4" day of October, 1999 Robinson O. Everett Attorney for the Plaintiffs Response to Request for Production #6 " we JOHN L. SANDERS 1107 SOURWOOD DRIVE CHAPEL HILL, NORTH CAROLINA 27514-4914 To: Robinson 0. Everett, Esquire From: John Sande Date: 22 Septem 999 Subject: Congressional districting contest rules, 1997 Here are the rules that you sent me for use in judging the entries in the congressional districting con- test "In 1997. Enclosed also is a statement that I issued at the time of the announcment of the results of the contest. These documents are from the file that I created at the time of the contest and that is still in my possession. EVERCTT GASKINS/DURHAM T 9-582-5469 Jan oe 16:06 No.005 P.01 CBE EAR, Sa, A.0. EVERETT (1878.1971) KATHERINE R. EVERETT (1821-1992) ROBINSON Q. EVERETT JAWN T, BATTISTE SANDRA @, HERRING , : : TEL $19) asa 103 : 1919) 383.241. OF COUNSEL ROBERT 0. HOLLEMAN FAX NUMBER: | 162-p45¢ Number of pages transmitted: Cover page plus Deseriprion of document From: 4 - Nd This facsimile sontgins PRIVILEGED AND CONFIDENTIAL INFORMATION intended only for the use of the addresses named above. [ff vou are not the intended recipient of this facsimile, or the employee or agent responsible for delivering it to the intended recipient, vou are hereby notified that any dissemination or copying of this facsimile is strictly prohibited. If you have received this faczimile in error please notity us ramediately by taphons and retum the original facsimile to us at the above address via the United States Postal Service. Thank you, ‘EVERETT GASKINS/DURHAM "a AMERICANS FOR THE DEFENSE OF CONSTITUTIONAL RIGHTS 301 West Main Street Suite 300 Durham, North Carolina 27701 Telephone: (919) 685-9659 Fax: (919) 682-5469 REDISTRICTING CONTEST Purpose of Contest: To determine whether one or more geographically compact majority-black congressional districts can be drawn in North Carolina. Definitions: 1) A "majority-black" congressional district is a district which contains within its boundaries one-twelfth of the total population of North Carolina, as shown by the 1990 census, and of which more than half of its total population is composed of African- Americans, as shown by the 1990 census. 2) A "geographically compact" congressional district is a district of which all parts are contiguous and which is "geographically compact" within the meaning of the Supreme Court's decisions in Shaw v. Reno, 509 U.S. 630 (1993), and Shaw v. Hunt, 116 S.Ct. 1894 (1996). Sponsor: Americans for the Defense of Constitutional Rights (ADCR), a North Carolina non-profit corporation. Eligible Contestants: Any citizen or resident of North Carolina, except officers or directors of ADCR, may participate in the competition. Legislators and public officials of the State are fully eligible to compete. Entries: No more than five entries may be submitted by each contestant, and the person submitting an entry must be identified by name and address. An entry may be prepared by use of the public access computer of the General Assembly in Raleigh ot by use of any other computer(s) that provide(s) adequate access to population data and census blocks information. An entry should contain a map showing the proposed majority-black district or districts and sufficient census information to show that more than half of the total population of each proposed district is African-American. Place and Time for Submission: To be considered, an entry must be received by February 10, 1997. Each entry should be mailed or hand-delivered to Americans for the Defense of Constitutional Rights, 301 West Main Street, Suite 300, Durham, North Carolina 27701. Jan we 16:06 No.005 P.02 EVERETT GASKINS/DURHAM 'o® Jan Ea 16:06 No.00S5S P.03 Prizes: First prize - $2,000.00 Second prize ~~ $1,000.00 Third prize —- $ 500.00 Contest Judge: The contest judge is Professor Emeritus John L. Sanders, who holds A.B. and J.D. degrees from the University of North Carolina; Professor Sanders served 38 years on the UN.C. Faculty, of which 33 years were with the Institute of Government -+ 25 years as its Director -- and five years as the University’s Vice President for Planning. From 1957 to 1985, Professor Sanders studied legislative representation in North Carolina and frequently advised the General Assembly on this and other topics, He has written extensively on legislative representation and on many other aspects of state and local government. Professor Sanders is serving as contest judge on a pro bono basis, but he may, at his own discretion, obtain such technical assistance as he believes will be helpful to him in judging the contest. The decision by Professor Sanders as contest judge will be final and is expected to be rendered on or before February 24, 1997. Rules: 1) The first prize of $2,000.00 will be given to the contestant who submits an entry showing two proposed majority-black congressional districts which are each geographically compact within the meaning of the Supreme Court’s Shaw opinions and are each totally separate from the other; ie, the district boundaries may touch but they may not overlap. If two contestants submit such an entry showing two such majority- black districts which are geographically compact, the prize will be awarded to the contestant whose entry in the judge's opinion best attains the goal of compactness. If two entries are identical, the prize will be awarded for the entry first received; 2) If the first prize is awarded, no second prize will be awarded. If no contestant qualifies for the first prize, the second prize of $1,000.00 will be awarded to the contestant who has submitted an entry showing one majority-black congressional district which in the judge’s opinion is the most geographically compact of those submitted; 3) If the first or second prize is awarded, no third prize will be awarded. Therefore, the third prize will be awarded only as a consolation prize and only if no entry received shows a proposed majority-black congressional district which in the judge's opinion is geographically compact. The recipient of the third prize will be the person whose entry contains a majority-black congressional district which in the judge's opinion comes closest to attaining geographical compactness. EVERETT GASKINS/DURHAM Tg ce oee Jan ve 16:07 No.005 P.04 americans for the Defensa of Constitutional Rights, Inc., (ADCR) is a non-profit corporation organized under the laws of North Caroline by the five original plaintiffs in Shaw v. Reno, 509 U.S. 630, 113 $.Ct, 2816 (1993). Because of their faith in the values of the Equal Protection Clause and thelr concern that racial garrymandars and racial quotas are endangering those values and exacerbating, rathar than reducing, racial divisions, these five citizens created ADCR. Among ANCR’/a missions are to inform the public about some of the odious practices which currently threaten tha goal of a “color blind society: urge logielatore and public officiale to enact laws and issue decrees that will meet theca threats) and, ac a last resort, te ancoeurage or even institute litigation to eliminate procedures, methodology, and sccial structures which tend to polarize our citizens along racial linex. we o® 2/22/97 CONGRESSIONAL DISTRICT PROPOSALS: EVALUATION PROCESS l. Nine district plans were submitted by a total of five persons. Each plan was examined in the following ways. 2. Does the proposed district contain appoximately one- twelfth of the state's 1990 total population of 6,628,637, or 552,386 people? Among the nine plans submitted, the maximum deviation from 552,386 was .67 of one per cent. No further consideration was given to this factor, since all nine plans were deemed to be acceptable by that measure. 3. Does the proposed district contain a majority of black residents? All nine of the districts evaluated were found to contain over 50 per cent black residents. No further consideration was given to percentages of black population, since all nine plans were deemed to be acceptable by that-measure. 4. One plan was rejected for extreme lack of compactness. It extended from Greensboro southwesterly to Charlotte and thence southeasterly to Sampson County. wh The remaining eight plans were submitted to the Legis-— lative Automated Systems Division of the General Assem- bly, which analyzed them for accuracy of population data and prepared large-scale maps that enabled ready comparison of seven of the plans. (The Division was unable to process the data provided by the consultant to the League of Women Voters, so that entry was evalu- ated on the basis of the population data and a small map provided by the consultant.) The Legislative Automated Data Systems Division cal- culated the area (in square miles) and the perimeter (in miles) of each of the seven proposed districts and applied to each district the Schwarzberg test to determine relative compactness. This test is applied by determining the shortest perimenter that would enclose the area of each proposed district (a circle) and dividing the actual perimenter by that shorter, eircular perimenter. The result is a ratio; the nearer that ratio is to 1.0, the more compact is the district. That test was used to determine the "one majority black congressional district which in the judge's opinion is the most geographically com- pact of those submitted." John Sanders 0 we 2/22/97 C ONGRESSIONAL DISTRICTING CONTEST WINNER ANNOUNCED On January 6, Americans for the Defense of Constitutional Rights, a Durham-based nonprofit foundation, announced a con- test to draw one or two geograpically compact, majority- black congressional districts for North Carolina, each con- taining one-twelfth of the state's 1990 population. A first prize of $2,000 was offered for the entry that showed two districts meeting those standards. If no entry met that condition, a second prize of $1,000 was offered for the "entry showing one majority-black congressional dis- trict which = in the judge's opinion is the most geograpi- cally compact of those submitted." If no first or second . prize was awarded, a third prize of $500 was offered for the "entry [that] contains a majority-black congressional district which in the judge's opinion comes closest to attaining geograpical compactness." Twelve persons (including a consultant who submitted an entry on behalf of the North Carolina League of Women Voters) submitted one or more plans each. No one proposed two acceptable compact and majority- black districts, so no first prize will be awarded. Six of the entries were found not to be responsive to the request for proposals because they did not offer plans for congressional districts. Instead, they proposed ae |g other schemes of election, such as at-large election of all twelve members of Congress from the entire state, which federal law does not permit. One entry was rejected because the dis- tricts it described were composed to contain majorities of "minority populations" and thus it was not responsive to the call for digeriers containing black majorities. Nine plans remained, the work of five contestants. One of those plans was found to be so obviously noncompact that it was rejected. The remaining eight plans, submitted by five contestants, were evaluated according to the procedures outlined in the attached memo. Each of the eight districts contains one-twelfth of the state's 1990 population. Each contains more than 50 per cent black population. Each consists of contiguous territory. All begin with the City of Durham on the west and range eastward along the Virginia line in quest of the ideal of 552,386 residents according to the 1990 census. On the basis of the Schwarzburg test, a mathematical measure of district compactness explained in the attached memo, Plan 1b submitted by Jack Daly of Raleigh is adjudged to be "the most geographically compact of those [plans] submitted" and is the winner of the second prize of $1,000. That district has a Schwarzburg ratio of 1.85 and a 1990 black majority of 50.18 per cent. (Mr. Daly also submitted 00 we the second most compact district plan, with a Schwarzburg ratio of 1.87 and a majority black population of 50.08 per cent. Qn John S anders at -» 2/22/97 CONGRESSIONAL DISTRICT PROPOSALS: EVALUATION PROCESS Nine district plans were submitted by a total of five persons. Each plan was examined in the following ways. Does the proposed district contain appoximately one- twelfth of the state's 1990 total population of 6,628,637, or 552,386. people? Among the nine plans submitted, the maximum deviation from 552,386 was .67 of one per cent. No further consideration was given to this factor, since all nine plans were deemed to be acceptable by that measure. Does the proposed district contain a majority of black residents? All nine of the districts evaluated were found to contain over 50 per cent black residents. No further consideration was given to percentages of black population, since all nine plans ware deevied to be acceptable by that measure. One plan was rejected for extreme lack of compactness. It extended from Greensboro southwesterly to Charlotte and thence southeasterly to Sampson County. » oe The remaining eight plans were submitted to the Legis- lative Automated Systems Division of the General Assem- bly, which analyzed them for accuracy of population data and prepared large-scale maps that enabled ready comparison of seven of the plans. (The Division was unable to Process the data provided by the consultant to the League of Women Voters, so that entry was evalis ated on the basis of the population data and a small map provided by the consultant.) The Legislative Automated Data Systems Division cal- culated the area (in square miles) and the perimeter (in miles) of each of the seven proposed districts and applied to each district the Schwarzberg test to determine relative compactness. This test is applied by determining the shortest perimenter that would enclose the area of each proposed district (a circle) and dividing .the actual perimenter by that shorter, eircular perimenter. The result is a ratio; the nearer that ratio is to 1.0, the more compact is the district. That test was used to determine the "one majority black congressional district which in the judge's opinion is the most geographically com- pact of those submitted." John Sanders TI TE A 2/22/97 CONGRESSIONAL DISTRICT PLANS COMPARED Total Percentage Sq. Mi. Actual Circular Schwarz- Author District Population Black Area Perimeter Perimeter berg Test Byrd, Tricia Turner la 552,576 51.10 5,754 623 269 2.32 Byrd, Tricia Turner 1b 552,226 51.04 5,783 581 270 2.16 Daly, Jack la 551,634 50.22 7,953 647 316 2.05 Daly, Jack 1b 551,214 50.18 7,893 584 315 1.85 3 Daly, Jack lc 552,222 50.08 7,785 586 313 1.87 Henderson, Diane (NCLWV) 1. 553,528 51.83 McDowell, Valecia 1 556,088 53.17 6,474 1,067 285 3.74 Robbins, Zachary L. 1 551,069 54.43 6,234 631 280 2.25 Ideal (1/12) 552,386 2/22/97 CONGRESSIONAL DISTRICT PLANS COMPARED Total Percentage Sq. Mi. Actual Circular Schwarz- Author District Population Black Area Perimeter Perimeter berg, Test Byrd, Tricia Turner la 552,576 51.10 5,754 623 269 2.32 Byrd, Tricia Turner 1b 352,226 51.04 5.783 581 270 2.16 Daly, Jack la 551,634 50.22 7,953 647 316 2.05 Daly, Jack 1b 551,214 50.18 7,893 584 315 1.85 3 Daly, Jack 1c 552,222 50.08 7,785 586 313 1.87 Henderson, Diane (NCLWV) 1 553,528 51.83 McDowell, Valecia 1 556,088 53.17 6,474 1,067 285 3.74 Robbins, Zachary L. 1 551,069 54.43 6,234 631 280 2.25 Ideal (1/12) 552,386 Ro an L JOHN L. SANDERS 1107 SourwooD Drive CHAPEL HILL. NORTH CAROLINA 27814 . 24 February 1997 Mr. Zachary L. Robbins 213 White Hall East Carolina University Greenville, North Carolina 27858 Dear Mr. Robbins: Thank you for your entry in the contest to design one Or two compact, majority-black congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. The decision was announced today. The enclosed press release and accompanying information explain the outcome of the contest and how it was reached. Yours, incidentally, was the only entry of the twelve that proposed two majority-black districts. Your southern district was sufficiently non-compact that it was not acceptable and was not analyzed in the same manner as the eight districts represented in the attached table. Your northern district (which I have designated as District 1) was one of the eight analyzed. Your map, together with the other seven that were analyzed, has been turned over to the General Assembly for its information and potential use in designing the new districts. ig Sincerely yours, Reson hn Sanders cc: Robinson 0. Everett, Esquire wh o® JOHN L. SANDERS 1107 S8OURwWOOD DRIVE CHAPEL HiLL. NORTH CAROLINA 27514 24 February 1997 Jack Daly Executive Director North Carolina Fund for Individual Rights, Inc. P.. 0. Box 31784 Raleigh, North Carolina 27622 Dear Mr. Daly: Thank you for your entries in the contest to design one or two compact, majority-black congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. Congratulations on having won the second prize in the contest. I gave you in Raleigh the press release and other information explaining how the decision was reached. Your maps, together with the other six that were analyzed, have been turned over to the General Assembly for its information and use in designing the new districts. Sincerely yours, re ie ohn Sanders cc: Robinson O. Everett, Esquire we oo’ JOHN L. SANDERS 1107 SouRwoOD DRIVE CHAPEL HiLL. NORTH CAROLINA 27514 + 24 February 1997 Valecia McDowell 3202 Myra Street, Apt. K Durham, North Carolina 27707 Dear Ms. McDowell: Thank you for your entry in the contest to design one or two compact, majority-black congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. The decision was accounced today. The enclosed press release and accompanying information explain the outcome of the contest and how it was reached. Your map, together with the other seven that were analyzed, has been turned over to the General Assembly for its information and use in designing the new districts. Sincerely yours, Seda hn Sanders cc: Robinsion O. Everett, Esquire oo’ we CHAPEL HILL, NORTH CAROLINA 27814 JOHN L. SANDERS 1107 S8ourRwooOD DRivE . 24 February 1997 Tricia Turner Byrd 6012 Carriage Oaks Drive Charlotte, North Carolina 28262 Thank you for your entries in the contest to design one or two compact, majority-black congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. The decision was announced today. The enclosed press release and accompanying information explain the outcome of the contest and how it was reached. Your maps, together with the other six that were analyzed, have been turned over to the General Assembly for its information and use in designing the new districts. Sincerely yours, Do n Sanders cc: Robinson 0. Everette, Esquire oP we CHAPEL HILL. NORTH CAROLINA 27514 JOHN L. SANDERS 1107 SsouRwooOD DRIVE 24 February 1997 Bernadette Parker President League of Women Voters of North Carolina Suite 311 3900 Barrett Drive Raleigh, North Carolina 27609-6614 Dear Ms. Parker: Thank you for the League of Women Voters' entry in the contest to design one or two compact, majority-black congressional districts for North Carolina. The desision was announced today. The enclosed press release and accompanying information explain the outcome and how it was reached. The data processors on the General Assembly staff never were able to import the data on your plan into their system, so I did not have two factors, area and perimenter length, that were available with respect to the other plans analyzed. I do not think that affected the outcome of the contest, however. Your map, together with the other seven that were analyzed, has been turned over to the General Assembly for its information and use in designing the new districts. Sincerely yours, A hn Sanders cc: Robinson 0. Everett, Esquire Diane Henderson oe we JOHN L. SANDERS 1107 SOoURWOOD DRIVE CHAPEL HILL. NORTH CAROLINA 27314 22 February 1997 Eddie Teachey 1353 River Dreams Road Raleigh, North Carolina 27610-8237 Dear Mr. Teachey: Thank you for your entry in the contest to design one or two majority-black, compact congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. The terms of the contest make it clear that it calls for one or two districts in which a majority of the resi- dents are black and which are geographically compact. Your entry shows the "minority population' for the counties and census tracts that compose your two proposed districts, but it does not show the black percentages of their popu- lations. Consequently, I am unable to determine from your data whether either of your proposed districts meets the terms of the contest. Therefore, I find that your entry is not responsive to the invitation for proposals. Sincerely yours, | TCC. hn Sanders cc: Robinson 0. Everett, Esquire o® " JOHN L. SANDERS 1107 SOURWOOD DRIVE CHAPEL HiLL. NORTH CAROLINA 27514 --22 February 1997 J. P. George 705 South First Street Smithfield, North Carolina 27577 Dear Mr. George: Thank you for your entry in the contest to design one or two compact, majority-black congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. Your proposal does not describe one or more congress- ional districts, although federal law requires that there be as many districts as there are members to be elected from the state, and therefore I find that it is not re- sponsive to the invitation for proposals. Sincerely yours, oe ASA ty ohn Sanders cc: Robinson 0. Everett, Esquire o® "wh JOHN L. SANDERS 1107 SOURWOOD DRivE CHAPEL HILL. NORTH CAROLINA 27314 22 February 1997 Leland O. Scott, Jr. 608 South Caswell Street LaGrange, North Carolina 28551 Dear Mr. Scott: Thank you for your entry in the contest to design one or two majority-black, compact congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. Since your proposal does not describe one or more con- gressional districts, although federal law requires as many districts as there are members to be elected, I find that it is not responsive to the invitation for proposals. Sincerely yours, lesen. ohn Sanders Robinson O. Everett, Esquire o® ot JOHN L. SANDERS 1107 SourRwoOD DRIVE CHAPEL HiLL, NORTH CAROLINA 27514 "22 February 1997 Emmett N. Bailey, Jr. 609 Soring Valley Road Henderson, North Carolina 27536 Dear Mr. Bailey: Thank you for your entry in the contest to design one or two compact, majority-black congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. Since your proposal does not describe one or more congressional districts, I find that it is not responsive to the invitation for proposals. Sincerely yours, IR ohn Sanders cc: Robinson O. Everett, Esquire o® wh JOHN L. SANDERS 1107 SOURWOOD DRIVE CHAPEL HILL. NORTH CAROLINA 27514 22 February 1997 Wayne Taylor 2623 Kirk Road Durham, North Carolina 27705 Dear Mr. Taylor: Thank you for your entry in the contest to design one or two compact, majority-black congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. Since your proposal merely depicts twelve arbitrarily drawn districts, withour information as to their populations, I find that it is not responsive to the invitation for pro- posals. Sincerely yours, st Las hn Sanders cc: Robionson O. Everett, Esquire ot dt JOHN L. SANDERS 1107 SourRwoOOD DRIVE CHAPEL HILL. NORTH CAROLINA 27514 22 February 1997 John D. B. Baston Aot. 10D LaSalle Street Durham, North Carolina 27705-3620 Dear Mr. Baston: Thank you for your entry in the contest to design one or two compact, majority-black congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. Since your proposal does not describe one or more con- gressional districts and federal law requires that there be as many districts as there are congressional seats to be filled by the state, I find that it is not responsive to the invitation for proposals. Sincerely yours, eOL.S hn Sanders cc: Robinson 0. Everett, .Esquire oh oe JOHN L. SANDERS 1107 SourRwoOD DRive CHAPEL HILL. NORTH CAROLINA 27514 +22 February 1997 Randy Crow 2119 Gloucester Place Wilmington, North Carolina 28403 Dear Mr. Crow: Thank you for your entry in the contest to design one or two compact, majority-black congressional districts for North Carolina, sponsored by Americans for the Defense of Constitutional Rights. Since your proposal does not describe your proposed congressional districts with necessary information about their populations and seems to contemplate assembling districts from non-contiguous areas, I find that it is not responisve to the invitation for proposals. Sincerely yours, SE \ NC ohn Sanders CC: Robinson 0. Everett, Esquire Response to Request for Production #8 League of Women Voters of North Carolina Redistricting Flan based on 1990 Csnaua Data Jariuary 1997 - LWVNC-1997 od ‘RATIONALE FOR REDISTRICTING PLAN January 1997 The League of Women Voters of North Carolina 1997 Redistricting Plan is based on the plan submitted by the League to the General Assembly and the Department of Justice in 1991 and 1992 but with modifications to provide a “majority-minority” district of over 50% black population. In 1992 we had argued that since a person could win a primary election with 40% of the vote, a minority candidate would have an excellent chance of election in a district having a black population greater than 40%, and had proposed two such districts. The African American population of North Carolina is not concentrated in any particular district, and it is very difficult to create a majority minority district that also follows good demographic principles like maintaining minor civil divisions (counties, cities and towns) and respecting geographic realities, as well as being compact and contiguous. In developing this plan, we have tried not to divide counties unless necessary to balance populations. Most divided counties are split between two districts, but in three cases it was necessary to divide counties into three districts in order to have a relatively compact district with enough minority voters to achieve slightly more than 50%. District 3, in addition, has a 32+% African American population, although not a majority minority district. Other considerations were to ensure adequate representation for various special interests, e.g. coastal interests — marine fisheries, tourism, beach protection — and the state’s military establishments, making sure that Ft. Bragg, Seymour Johnson AF B, Camp Lejeune, and the Army Corps of Engineers sites were not all included in a single district. Similarly, there are multiple districts representing mountainous parts of the state, and several fairly compact more-or-less urban districts. No partisan political information — voting registration, incumbent Congressional representation — was used. Since there is no requirement in the federal or state Constitution for residency in the Congressional district one represents, there is nothing in this plan to preclude the present incumbents’ running in a different district. The plan submitted in 1992 was prepared using an intermediate level of data aggregation which the General Assembly’s data processing personnel were not able to relate to their data bases. This time, we have used the Census Block-level data (SUMLEV=75 0, in a database of about 28 MB containing over 150,000 records). For the divided counties, we can provide DBF format data files compressed onto two floppy disks rather than printing the detailed lists, which would run to hundreds of pages. Mapinfo Professional 4.1 Desktop Mapping software was used for the work. (In 1992 we used version 2.0 of Mapinfo). All data used by LWVNC come from the Census of Population and Housing, 1990: Public Law (P.L.) 94-171 Data on CD-ROM (North Carolina) [machine readable data files] / prepared by the Bureau of the Census, — Washington: The Bureau [producer and distributor], 1991. There is generally no information on voting precincts in the North Carolina data, so it is difficult to try to avoid dividing these. If there are questions about these materials, please contact Diane Henderson, Redistricting consultant to the LWVNC Board. Phone 919-261-2689; fax 919-261-7437 ; e-mail, nhendrsn@jinterpath.com. we Total Variation Percent Minority Percent District Perimet population from desired variation Popu- Minority Size (sq. er LWVNC-1997 January 1997 District Popu- lation O C O o O N O T O P E L W N == 553,528 553,321 552,654 551,695 552,395 551,976 551,142 552,383 553,178 552,505 551,473 552,387 number 1142 935 268 -691 9 -410 -1244 -3 792 119 -913 1 from 552386 0.21% 0.17% 0.05% -0.13% 0.00% -0.07% -0.23% 0.00% 0.14% 0.02% -0.17% 0.00% lation 286,886 141,889 177,526 120,141 112,503 125,246 137,737 144,097 66,263 88,863 50,402 29,276 Popu- lation 51.8% 25.6% 32.1% 21.8% 20.4% 22.7% 25.0% 26.1% 12.0% 16.1% 9.1% 5.3% mi.) 5,500 11,180 4,947 2,386 4,976 1,894 5,574 477 3,145 3,528 3,296 6,581 548.5 662.6 325.2 246.6 403.8 258 491.8 119.6 281.4 333.4 336.3 409.3 density 101 49 112 231 111 291 99 1158 176 157 167 84 6,628,637 Notes to the comparison statistics: 1. The deviations from the desired number of 552,386 are quite small. Formerly, plus or minus 1% was considered permissible in redistricting, but with computers, we can do better. The maximum deviation here is -0.23% for District 7. All deviations in this plan are less than one-quarter of one percent, well within the permissible range. 2. District size in square miles is derived from the region sizes by the mapping software. They are based on polygons that had to be drawn by hand due to lack of any closed figures in the map, and should be considered only approximations. The same approximation problem occurs with the perimeters; they are useful for comparison purposes, but not definitive. 3. The population density was calculated primarily to show the extreme variations of density among different regions. The coastal plain, full of bays and estuaries and wetlands, is the most sparsely settled. Mountain areas have similar characteristics for different reasons. LWVNC 1997 Redistricting Plan » Counties and parts of Counties by District Black Total Popu- Popu- Percent County District lation lation Black BERTIE 1 20,388 12,531 61.46% Durham 1 91,916 59,724 64.98% EDGECOMBE 1 56,558 31,661 55.98% GATES 1 9,305 4,180 44.92% Granville 1 24,918 10,946 43.93% HALIFAX 1 55,516 27,586 49.69% HERTFORD 1 22,523 12,970 57.59% Martin 1 19,971 10,065 50.40% Nash 1 54,850 15,919 29.02% NORTHAMPTON 1 20,798 12,328 59.27% Pasquotank 1 19,458 9,730 50.01% Perquimans 1 6,480 2,702 41.70% Pitt 1 45,224 23.827 52.69% VANCE 1 38,892 17,512 45.03% WARREN: 1 17,265 9,847 57.03% Washington 1 6,173 3,663 59.34% Wilson 1 43,293 21,695 50.11% Totals, District 1 553,528 286,886 51.83% BEAUFORT 2 42,283 13,194 31.20% CAMDEN 2 5,904 1,481 25.08% CARTERET 2 52.656 4,385 8.34% CHOWAN 2 13,506 5,087 37.66% CRAVEN 2 81,613 21.116. 25.87% CURRITUCK 2 13,736 1,845 11.25% DARE 2 22,746 811 3.57% GREENE 2 15,384 6,521 42.39% HYDE 2 5,411 1.781 32.91% Johnston 2 17,091 2.273 13.30% JONES 2 9,414 3,677 39.06% LENOIR 2 57,274 22.539 - 30.35% Martin 2 5,107 1.121. 21.95% Onslow 2 5,071 697 13.74% PAMLICO 2 11.372 2,951 25.95% Pasquotank 2 11,840 1,853 - 15.85% Perquimans 2 3,967 724 18.25% Pitt 2 62,700 12,094 19.29% TYRRELL 2 3,856 1,543 40.02% Washington 2 7,824 2,703. 34.55% WAYNE 2 104,666 33,793 32.20% Totals, District 2 553,321 141,889 25.64% BLADEN 3 28,663 11,199 39.07% Cumberland 3 253,067 97,269 38.44% DUPLIN 3 39,995 13,2590 33.15% New Hanover 3 10,010 2,232 22.30% Onslow 3 144,767 29,111 20.11% January 1997 Page 1 of 3 Page 2 of 3 LWVNC 1997 Redistricting Plan Counties and parts of Counties by District PENDER SAMPSON Totals, District 3 Durham FRANKLIN Granville Johnston Nash Wake Wilson Totals, District 4 Alamance CASWELL CHATHAM Durham Granville HARNETT LEE MOORE ORANGE PERSON Randolph Wake Totals, District 5 R O E R O E E O E R LR G Re Alamance Forsyth GUILFORD ROCKINGHAM STOKES Totals, District 6 ANSON BRUNSWICK COLUMBUS Cumberland HOKE Mecklenburg New Hanover RICHMOND ROBESON SCOTLAND UNION . Totals, District 7 Gaston Mecklenburg Totals, District 8 3 3 EN E SE NE [e ) BN e ) I N e ) Be ) I e ) N N N N N N N N N N N (o } 28,855 47,297 552,654 7,183 36,414 8,501 64,215 21,827 390,787 22,768 551,695 44,176 20,693 38,759 82,736 4,926 67,822 41,374 59,013 93,851 30,180 36,272 32,593 552,395 64,037 17,232 347,420 86,064 37,223 551,976 23,474 50,985 49,587 21,499 22,856 4,805 110,274 44,518 105,179 33,754 84,211 551,142 89,472 462,911 552,383 8,770 15,686 177,526 662 12,843 2,010 12,116 8,223 81,086 3,201 120,141 7,849 8,436 8,845 16,268 1,953 15,315 9,401 10,882 14,893 9,106 2,584 6,971 112,503 12,973 1,001 91,655 17,548 12,069 125,246 11,106 9,211 15,181 5,733 9,878 106 21,865 12,869 26,185 12,176 13,427 137,737 14,820 129,277 144,097 30.39% 33.16% 32.12% 9.22% 35.27% 23.64% 18.87% 37.67% 20.75% 14.06% 21.78% 17.77% 40.77% 22.82% 19.66% 39.65% 22.58% 22.72% 18.44% 15.87% 30.17% 7.12% 21.39% 20.37% 20.26% 5.81% 26.38% 20.39% 5.56% 22.69% 47.31% 18.07% 30.61% 26.67% 43.22% 2.21% 19.83% 28.91% 24.90% 36.07% 15.94% 24.99% 16.56% 27.93% 26.09% January 1997 A 1997 Redistricting Plan i Counties and parts of Counties by District CABARRUS 9 98,935 12,853 12.99% DAVIDSON 9 126,677 12,314 9.72% DAVIE 9 27,859 2,482 8.91% Mecklenburg 9 43,717 5085 11.63% MONTGOMERY 9 23,346 6,001 25.70% Randolph 9 70,274 3,783 5.38% ROWAN 9 110,605 17.773 16.07% STANLY 9 51,765 5972 11.54% Totals, District 9 553,178 66,263 11.98% ALEXANDER 10 27,544 1,673 6.07% ALLEGHANY 10 9,590 177 1.85% ASHE 10 22,209 144 0.65% Forsyth 10 248,646 65,101 26.18% IREDELL 40 92,931 14,869 16.00% SURRY 10 61,704 2,780 4.51% WILKES 10 59,393 2,824 4.75% YADKIN 10 30,488 1,295 4.25% Totals, District 10 552,505 88,863 16.08% AVERY 11 14,867 158 1.06% BURKE 11 75,744 5,178 6.84% CALDWELL 11 70,709 3,881 5.49% CATAWBA 11 118,412 10,689 9.03% CLEVELAND 11 84,714 17,741 20.94% Gaston 11 85,621 7,856 9.18% LINCOLN 11 50,319 4,108 8.16% Mitchell 11 14,135 23 0.16% WATAUGA 11 36,952 768 2.08% Totals, District 11 : 551,473 50,402 9.14% BUNCOMBE 12 174,821 14,336 8.20% CHEROKEE 12 20,170 361 1.79% CLAY 12 7.155 41 0.57% GRAHAM 12 7,196 1 0.01% HAYWOOD 12 46,942 648 1.38% HENDERSON 12 69,285 2,361 3.41% JACKSON 12 26,846 425 1.58% MACON 12 23,499 385 1.64% MADISON 12 16,953 136 0.80% MCDOWELL 12 35,681 1,479 4.15% Mitchell 12 298 0 0.00% POLK : 12 14,416 1,053 7.30% RUTHERFORD 12 56,918 6,514 11.44% SWAIN 12 11,268 196 1.74% - TRANSYLVANIA 12 25,520 1,189 4.66% YANCEY 12 15,419 151 0.98% Totals, District 12 552,387 29,276 5.30% Names of divided Counties appear in bold type. January 1997 Page 3 of 3 ne Alphabetic Listing of Counties we LWVNC 1997 Plan TOTAL BLACK POPU- POPU- COUNTY NAME District LATION LATION % BLACK Alamance 5 44,176 7849 17.77% Alamance 64,037 12,973 20.26% ALEXANDER 27,544 1,673 40.77% ALLEGHANY 9,590 177 9.03% ANSON 23,474 11,106 47.31% ASHE 22,209 144 22.82% AVERY 14,867 158 25.87% BEAUFORT 42,283 13,194 49.69% BERTIE 20,388 12,531 61.46% BLADEN 28,663 11,199 39.07% BRUNSWICK 50,985 9,211 18.07% BUNCOMBE 174,821 14,336 19.66% BURKE 75,744 5178 38.44% CABARRUS 98,935 12,853 12.99% CALDWELL 70,709 3,881 26.67% CAMDEN 5,904 1,481 22.58% CARTERET 52,556 4,385 1.38% CASWELL 20,693 8,436 40.77% CATAWBA 118,412 10,689 11.25% CHATHAM 38,759 8,845 22.82% CHEROKEE 20,170 361 55.98% CHOWAN 13,506 5,087 3.41% CLAY 7,155 41 5.81% CLEVELAND 84,714 17,741 3.57% COLUMBUS 49,587 15,181. 30.61% CRAVEN 81,613 21.116. © 57.59% Cumberland 253,067 97,269 38.44% Cumberland 21,499 5,733. 26.67% CURRITUCK 13,736 1,545 43.22% DARE 22,746 811 32.91% DAVIDSON 126,677 12,314 9.72% DAVIE 27,859 2,482 8.91% DUPLIN 39,995 13,250 33.15% Durham 91,916 59,724 64.98% Durham 7,183 662 9.22% Durham 82,736 16,268 19.66% EDGECOMBE 56,558 31,661 55.98% Forsyth 248,646 65,101 1.79% Forsyth 17,232 1,001 5.81% FRANKLIN 36,414 12,843 35.27% Gaston 85,621 7,856 9.72% Gaston 89,472 14,820 16.56% . GATES 9,305 4,180 1.85% GRAHAM 7,196 1 26.18% Granville 24,918 10,946 47.31% Granville 8,501 2,010 19.83% Granville 4,926 1,053 39.65% GREENE 15,384 6,521 16.00% N O B A T 2 0 g O R W O O N N N ® O N N Page 1 of 3 January 1997 * : Alphabetic Listing of Counties » LWVNC 1997 Plan GUILFORD 6 347,420 91,655 26.38% HALIFAX 3 55,516 27,586 0.65% HARNETT 5 67,822 15,3156 22.58% HAYWOOD 12 46,942 648 35.27% HENDERSON 12 69,285 2,361 16.56% HERTFORD 1 22,523 12,970 1.06% HOKE 7 22,856 0,878 43.22% HYDE 2 5,411 1,781 1.58% IREDELL 10 92,931 14,869 37.66% JACKSON 12 26,846 425 9.18% Johnston 2 17,091 2273 13.30% Johnston #4 64,215 12,116 59.27% JONES 2 9,414 3,677 18.87% LEE 5 41,374 9,401 22.72% LENOIR 2 57,274 22,539 39.06% LINCOLN 11 50,319 4,108 8.16% MACON 12 23,499 385 1.64% MADISON 12 16,953 136 0.80% Martin 1 19,971 10,065 50.40% Martin 2 5,107 1.121. 21.95% MCDOWELL 12 35,681 1,479 4.15% Mecklenburg 7 4,805 106 2.21% Mecklenburg 8 462,911 129.277 27.93% Mecklenburg 9 43,717 5085 11.63% Mitchell 11 14,135 23 0.16% Mitchell 12 298 0 0.00% MONTGOMERY 9 23,346 6,001 25.70% MOORE 5 59,013 10,882 18.44% Nash 1 54,850 15,919 29.02% Nash 4 21,827 8,223 37.67% New Hanover 3 10,010 2232 22.30% New Hanover 7 110,274 . 21.865 19.83% NORTHAMPTON 1 20,798 12,328 39.07% Onslow 2 5,071 697 39.35% Onslow 3 144,767 20,111 20.11% ORANGE 5 93,851 14,893 15.87% PAMLICO 2 11,372 2,951 25.95% Pasquotank 1 19,458 9,730 50.01% Pasquotank 2 11,840 1,853 15.65% PENDER 3 28,855 8,770 30.39% Perquimans 1 6,480 2,702 41.70% Perquimans 2 3,967 724 18.25% PERSON 5 30,180 9,106 30.17% Pitt 1 45,224 23,827 52.69% Pitt 2 62,700 12,094 19.29% POLK 12 14,416 1,053 7.30% Randolph 5 36,272 2,584 7.12% Randolph 9 70,274 3,783 5.38% RICHMOND / J 44,518 12,869 28.91% ROBESON 1 105,179 26,185 24.90% ROCKINGHAM 6 86,064 17,548 20.39% Page 2 of 3 January 1997 Alphabetic Listing of Counties we LWVNC 1997 Plan ROWAN 110,605 17,773 . 16.07% RUTHERFORD 56,918 6,514 . 11.44% SAMPSON 47,297 15,686 33.16% SCOTLAND 33,754 12,176 36.07% STANLY 51,765 5972 11.54% STOKES 37,223 2,069 5.56% SURRY 61,704 2,780 4.51% SWAIN 11,268 196 1.74% TRANSYLVANIA 25,520 1,189 4.66% TYRRELL 3,856 1,543 40.02% UNION 84,211 13,427 15.94% VANCE 38,892 17,512 45.03% Wake 390,787 81,086 20.75% Wake 32,593 6,971 21.39% WARREN 17,265 9,847 57.03% Washington 6,173 3,663 59.34% Washington 7,824 2,703 34.55% WATAUGA 36,952 768 2.08% WAYNE 104,666 33,793 32.29% WILKES 59,393 2,824 4.75% Wilson 43,293 21,695 50.11% Wilson 22,768 3,201 14.06% YADKIN 30,488 1,295 4.25% YANCEY 15,419 151 0.98% 6,628,637 County names in bold type indicate the county is divided. Page 3 of 3 January 1997 League of A‘om an voters of North Carolina October:198 1 Proposed Redintricting Pan LWVNC-1997 District - — w e b a h S o o 0 w o N o a h O N = Total popu- lation 552,386 552,389 552,384 552,383 552,386 552,392 552,387 552,386 552,383 552,387 552,385 552,389 6628637 EE January 1997 Comparison Statistics for LWVNC 1991 Plan Percent Minority Percent District Varia- tion variation from from desired 552386 number 0 0.000% 3 0.001% -2 0.000% -3 -0.001% 0 0.000% 6 0.001% 1 0.000% 0 0.000% -3 -0.001% 1 0.000% -1 0.000% 3 0.001% Notes to the comparison statistics: Popu- lation 246,380 145,471 123,657 149,412 118,500 147,558 185,027 136,840 96,381 53,489 56,600 29,276 Peri- Minority Size (sq. meter Popu- lation 44.60% 26.33% 22.39% 27.05% 21.45% 26.71% 33.50% 24.77% 17.45% 9.68% 10.25% 5.30% mi.) 6,823 10,330 4,564 2,301 3,428 2,273 6,488 776 2,034 3.817 3,534 6,553 561.8 722.5 341.5 248.3 330.7 370.2 524.7 128.6 298.9 409.1 472.7 418.3 Popu- lation density 80.96 53.47 121.03 240.06 161.14 243.02 85.14 712.30 271.57 144.72 156.31 84.30 1 The deviations from the desired number of 552,386 are quite small. All deviations in this plan are less than one-tenth of one percent, well within the permissible range. 2. District size in square miles is derived from the region sizes by the mapping software. They are based on polygons that had to be drawn by hand due to lack of any closed figures in the map, and should be considered only approximations. The same approximation problem occurs with the perimeters; they are useful for comparison purposes, but not definitive. 3. The population density was calculated primarily to show the extreme variations of density among different regions. The coastal plain, full of bays and estuaries and wetlands, is the most sparsely settled. Mountain areas have similar characteristics for different geographic reasons. L ! LWVNC. Proposed Alternative ~ congressional: Plan, Revision x, Ly / 22 oa + District Cowity Population White Black esr Black a 015 Bertie County : 20388 7790 12531 61.46 065 Edgecombe County . 56558 24665 31661 55.98 073 Gates County 9305. 5101 - 4180 44.92 077 Granville County 38345 23069 14909 38.88 079 Greene County 15384 8747 6521 42.39 083 Halifax County 55516 26009 27586 49.69 . 091 Hertford County 22523 9214 12970 57.59 | 117 Martin County 25078 13788 11186 44.60 | 127 Nash County (01) © 58685 39235 18943 32,28 | 131 Northampton County 20798 8397 12328 59.27 139 Pasquotank County 31298 19403 11583 37. 01] 143 Perquimans County : 10447 6979 3426 32.79 | 147 Pitt County (01) 74586 45507 28057 37. 62 181 Vance County 38892 21146 17512 45.03 | 185 Warren County 17265 6593 9847 57.03 | 195 Wilson County (01) 57318 33767 23140 40.37 | Subtotal: DISTRICT = 01, 16 records. 552,386 299,410 246,380 44.60% District County Population ~~ White Black Percent Black 02 013 Beaufort County 42283 28949 13194 31.20 029 Camden County 5904 4388 1481 25.08 031 Carteret County 52556 47445 _. 4385 8.34 041 Chowan County 13506 8349 © 5087 37.66 049 Craven County 81613 58660 21116 25.87 053 Currituck County 13736 12051 1545 11.25 055 Dare County 22746 21766 811 3.97 095 Hyde County 5411 3596 1781 32.91 103 Jones County 9414 5687 - 3677 39.06 107 Lenoir County 57274 34322 22539 39.35 133 Onslow County (02) 80717 58850 17338 21.48. 137 Pamlico County 11372 8362 2951 25.95 147 Pitt County (02) 33338 25136 7864 23.59 177 Tyrrell County ©3856 © 2297 1543 40.02 187 Washington County 13997 7556 6366 45.48 191 Wayne County . . 104666 69172 33793 32.29! Subtotal: DISTRICT = 02, 16 record 552,389 396,586 145,471 26.38% District County =—===-- population ~ White --—-Black Percent Black = 03 051 Cumberland CoE] -197158 138778 45663 23.14 %% 061 Duplin County 39995 25927 13259 33.15. 085 Harnett County 67822 51117 15315 22.58 101 Johnston County (03) 10416 8611 ~- 1635 15.70 129 New Hanover County (03) 91876 83733 "7071 16.13 *% 133 Onslow County (03) 69121 53089 12540 18.14 Eg ae LWVNC Proposed Alternative Plan, Rev. 1 Ee January 1992 - Page 2 141 Pender County 28855. 19828 8770 30.39 163 Sampson County 47297 30273 15686 33.16 Subtotal: DISTRICT = 03, 3 recor. 52,384 410,753 123,657 2. 72% ue District County or Population white Back Percent Black 04 069 Franklin County T3644 23288 12843 35.2] 101 Johnston County (04)%+ 70890 57162 12754 17.99 127 Nash County (04) 17992 12639 5199 28.90 183 Wake County (04) 418344 319183 87193 20.84 195 Wilson County (04) 8743 6856 1756 20.08 Subtotal: DISTRICT = O04, 5 records. 552,383 419,128 119,745 21.67% > | | District County Population ~~ White = Black Percent Black 05 001 Manance County (05) 81645 62315 ~~ 19330 23.68 033 Caswell County 20693 12155 8436 40.77 037 Chatham County .. 38759 29423 8845 22.82 063 Durham County 181835 109886 67654 37.21 105 Lee County 41374 31216 9401 22.72 125 Hoore County 59013 47464 10882 18,44 135 Orange County 93851 75871 14893 15.87 145 Person County 30180 20740 9106 30.17 183 Wake County (05) 5036 4227 865 17.18 Subtotal: DISTRICE = 05, 9 records. 552,386 = 393,207 149,412 27,058 District County Population White Black Percent Black 06 001 Alamance County (06) 26568 24445 2164 8.15 081 Guilford County 347420 249584 91655 26.38 151 Randolph County (06) 63930 57341 © 5350 3.37 157 Rockingham County 86064 67893 17548 20.39 169 Stokes County (06) 28410 26855 1783 6.28 Subtotal: DISTRICT = 06, 5 records. 552,392 426,618 118,500 21.45% District County Population =~ White Black: Percent Black 07 007 Anson County 23474 12264 11106 47.31 017 Bladen County 28663 16926 11199 39.07 019 Brunswick County 50985 41336 9211 18.07 047 Columbus County 49587 32897 15181 30.61 051 Cumberland County (07) 77603 31292 41833 54.04 #4 093 Hoke County il a 22856 9635 9878 43.22 123 Nontqomery County (07) 21097 14650 5885 27.89 .129 New Hanover County (07) 28564 11200 17144 60,09 &# 153 Richuond County A518 30816 12869 28.91 . .° FE ——— 105179 37986 26185 24.90 155 Robeson County t+ changed from initial LAVEC proposal of 10/15/91 | i 12176 36.07 12423 19.32 | 552,387 311,530 185,027 33.49% ** Non-white population 43.60% | : LWVNC Proposed Alternative Plan, Rev. 1 January 1992 Page 3 - 33754 64311 165 Scotland County 179 Union County (07) 19025 51316 _ Subtotal: DISTRICT = 07, 12’ records. District County Population White Black Percent Black 08 025 Cabarrus County (08) 23048 23390 1429 6.20) 119 Hecklenburg County 511433 364651 134468 26:23 179 Union County (08) 17909 16788 943 5.27 Subtotal: DISTRICT = 08, 3 records. 552,386 404,829 136,840 24,778 District County Population White Black Percent Black 09 025 Cabarrus County (09) 75891 63896 11424 15.05. 057 Davidson County (09) . 102034 89544 _ 11592 11.36 067 Forsyth County 265878 196918 66102 24.86 123 Nontgomery County. (09) 2249 2120 116 5.16 151 Randolph County (09) 42616 41209 1017 2.39 159 Rowan County (09) 11950 11718 158 1.32 167 Stanly County 51765 45269 5972 11.54 Subtotal: DISTRICT = 09, 7 records. 562,383 450,674 96,381 17.45% District County Population =~ White Black Percent Black 10 003 Alexander County 27544 25667 1673 6.07. 005 Alleghany County 9590 9338 177 1.85 027 Caldwell County 70709 66506 3881 5.49 035 Catawba County (10) 71677 64882 5851 8.16 057 Davidson County (10) 24643 23752 722 52.93 059 Davie County 27859 25194 2482 8.91 097 Iredell County : 92931 77207 14869 16.00 159 Rowan County (10) .—.... 98655 80133 17615 17.86 169 Stokes County (10) 8813 ' 8473 286 3.25. 171 Surry County 61704 58383 2780 4.51 193 Wilkes County (10) 27774 25696 1858 6.69 197 Yadkin County 30488 28884 1205 4.25 Subtotal: DISTRICT = 10, 12 records. 552,387 494,115" 53,489 9.68% District County Population ~~ White Black Percent Black 11 009 Ashe County 22209 21960 144 0.65 011 Avery County 14867 14596 158 1.06 023 Burke County : 75744 69521 5178 6.84 035 Catawba County (11) - 46735 41488 4838 10.35) 045 Cleveland County 34714 66362 17741 20.94 071 Gaston County 175093 150868 22676 12.95 109 Lincoln County 50319 45710 © 4108 8.16 121 Mitchell County (11) 14133 14054 23 0.16, LHVNC Proposed Alternative Plan, Rev. 1 January 1992 Page 4 EE © 189 Watauga Comty . .. 36952 35930 768 2. 193 Wilkes County (11) © . L619 35M 966 .3.06 Subtotal: DISTRICE = 11, 10 records. 552,385 491,000 56,600 10.23% ~ District County m= Population- White - - Black Percent Black. .: . 12 021 Buncombe County. 174821 158979 14336 8.20) 039 Cherokee County = 0170 19313 361 1.79) 043 Clay County 7155 7061 41 0.57) . 075 Graham County 7196 673% L.o.0n 087 Haywood County 46942 46011. 648 1.38 089 Henderson County 69285 66158 2361 3.41 1099 Jackson County 26846 23609 425 1.58 111 McDowell County 35681 33901 1479 4.15, 113 Kacon County 23499 22919 385 1.64] 115 Kadison County 16953 16744 136 0.80) 121 Nitchell County (12) 300 300 0 0.00, 149 Polk County 14416 13276 1053 7.30 161 Rutherford County = 56918 50133 6514 11.44 173 Swain County 11268 7950 - 19% 1.74 175 Transylvania County 25520 24121 1189 4.66) 199 Yancey County 15419 15221 151 0.98 Subtotal: DISTRICT = 12, 16 records. 552,389 512,427 29,276 5.30 Ng North Carolina Totals: 6,628,637 5,010,789 1,456,948 21.98% " » LWVNC Position on Redistricting Adopted by the state board March 4, 1994, based on concurrence of local Leagues The League of Women Voters of North Carolina believes that: Congressional districts, both houses of the state legislature, and county and municipal government districts including boards of education should be apportioned primarily on population. Districts should be single- member*, compact, convenient, contiguous and reflect a community of interest. Specific standards for fair representation as required by the Voting Rights Act should be assured. The responsibility for redistricting and reapportioning should rest with an independent agency commissioned by the legislature once every ten years; the agency plan (for redistricting) should be submitted for legislative approval without amendment. The independent agency should not be a court. The agency should reflect the geographic, racial, and gender make-up of the state population, but no elected official should be a member. As a creature of the legislature, the agency would be subject to the Open Meetings law. Definite provisions should be made for compensation and staff services of the independent agency. A process should be provided to effect automatic, compulsory, periodic redistricting and reapportioning. Measures to enact this process should include authority, enforcement powers, time schedule and funding. The specific measure may take the form of a constitutional amendment or legislation. Specific provisions should be made for court review of redistricting and reapportioning measures and for courts to require the independent agency to act on a specific schedule. The state and its political subdivisions should be redistricted and reapportioned every ten years within a year of certification of the census. Definite time limits should be set for an agency to act after the decennial census figures are available in order to comply with federal Voting Rights legislation.. Time limits should be set for initiating court action for review of constitutionality of measures. * Required by current federal law for Congressional districts i, : |} Board of Directors President Marian Dodd Raleigh First Vice President Katherine Colwell Pinehurst Second Vice President Jane Warsaw North Topsail Beach Secretary Pauline Joos Jacksonville Treasurer Jana Albritton Wilmington Directors Sherry Kelly Greensboro Beth Lazer Asheville Judith McLeod Marshall Maethel Shindelman Franklin Kathryne Thompson Nags Head SandraTrivett Asheville Office League of Women Voters of orth Carolina May 21, 1998 Mr. David Daniel Clerk of Court U. S. District Court Box 25670 Raleigh, North Carolina 27611 Subject: Alternative proposal for Congressional Districts in North Carolina. Dear Mr. Daniel: The League of Women Voters of North Carolina proposes an alternative proposal to the Congressional Redistricting plan adopted by the General Assembly of North Carolina. As you can see from the 1991 plan is less convoluted than later ones which considered racial minority voters more, and earlier maps are better in some respects because they divide fewer counties. Other considerations ensure adequate representation for special coastal interest--marine fisheries, beach protection and tourism, state's military establishments, multiple districts representing mountainous part of the state, and several fairly compact more-or-less urban districts. In designing the maps no partisan political information, voting registration, incumbent congressional representation was used. Since there is not a requirement in the Federal or State Constitution for residency in the congressional district one represents, there is nothing in this plan to preclude the present incumbents running in a different district. In regard to the past history for redistricting plans, it indicates the need to reexamine a new approach in designing districts. Through research, the league reached a consensus in 1994, that redistricting and reapportioning should rest with an Independent Commission for adoption ject m embers. League of Women Voters of NE rejection, without an amend ent, by General Asserbly m 3900 Barrett Dr Ste 311 Raleigh, NC 27609-6614 Phone and Fax 919-783-5995 1-800-851-VOTE In 1991-1992 plans were submitted to the Department of Justice and the General Assembly. In 1997 a plan was submitted to a sponsored os 4 group for a redistricting contest and to the General Assembly. In 1998, an alternate proposal was submitted to the chairs of the Redistricting Committee of the General Assembly and a presentation was made during a public hearing for congressional redistricting. In the event, the General Assembly plan is rejected by the court, the League of Women Voters submits an alternative plan to the court for Congressional redistricting, and a copy was submitted to the plaintiff. Sincerely, he J gn aan. Bel ” Marian Dodd, State President League of Women Voters NC CC: Judge Robinson Everett Diane Henderson, 919.261.7437