Defendants' Answers to United States' First Set of Requests for Admission; Defendants' Answers to United States' First Set of Interrogatories; House Bills No. 637, 149, 1630; Senate Bill No. 65

    IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF LOUISIANA 

RONALD CHISOM, et al., 

Plaintiffs, 

UNITED STATES OF AMERICA, 

Plaintiff-intervenor, CIVIL ACTION NO. 

86-4075 
versus • 

: Section A 
CHARLES E. ROEMER, et al., 

Defendants. 

DEFENDANTS' ANSWERS TO UNITED STATES' FIRST  
SET OF REQUESTS FOR ADMISSION  

Now into Court, through undersigned counsel come the 

defendants, CHARLES E. "BUDDY" ROEMER, in his capacity as 

Governor of the State of Louisiana; FOX McKEITHEN, in his 

capacity as Secretary of State of Louisiana; and JERRY M. FOWLER, 

in his capacity as Commissioner of Elections of the State of 

Louisiana, who, for their answers to the United States' First Set 

of Requests for Admission, show: 

Request for Admission No. la: 

According to the 1980 Census, the State of Louisiana 

had a population of 4,205,900 of whom 1,238,241 (29.44%) were 

black persons. 



Answer to Request for Admission No. la: 

Paragraph la is admitted. 

Request for Admission No. 2a: 

The census further indicated that there were 2,875,432 

persons eighteen (18) years of age or older (voting age 

population or "VAP") of whom 766,187 (26.44%) were black persons. 

Answer to Request for Admission No. 2a: 

Paragraph 2a is admitted. 

Request for Admission No. 3a: 

The Louisiana Supreme Court consists of seven members 

elected in public elections to ten-year terms. 

Answer to Request for Admission No. 3a: 

Paragraph 3a is admitted. 

Request for Admission No. 4a: 

For purposes of electing members of the state supreme 

court the state is divided into five single-judge election 

districts and one multi-judge election district. 

Answer to Request for Admission No. 4a: 

Paragraph 4a is admitted. 

Request for Admission No. 5a: 

The supreme court election districts are comprised of 

the following parishes: 

First district: Orleans, St. Bernard, 
Plaquemines and Jefferson. 



Second district: Caddo, Bossier, Webster, 
Claiborne, Bienville, Natchitoches, Red 
River, Desoto, Winn, Vernon and Sabine. 

Third district: Rapides, Grant, Avoyelles, 
Lafayette, Evangeline, Allen, Beauregard, 
Jefferson Davis, Calcasieu, Cameron and 
Acadia. 

Fourth district: Union, Lincoln, Jackson, 
Caldwell, Ouachita, Morehouse, Richland, 
Franklin, West Carroll, East Carroll, 
Madison, Tensas, Concordia, LaSalle, and 
Catahoula. 

Fifth district: East Baton Rouge, West Baton 
Rouge, - West Feliciana, East Feliciana, St. 
Helena, Livingston, Tangipahoa, St. Tammany, 
Washington, Iberville, Point Coupee, and St. 
Landry. 

Sixth district: St. Martin, St. Mary, 
Iberia, Terrebonne, Lafourche, Assumption, 
Ascension, St. John the Baptist, St. James, 
St. Charles, Vermillion. 

Attachment A is a map of Louisiana which accurately indicates the 

supreme court election districts. 

Answer to Request for Admission No. 5a: 

Paragraph 5a is admitted. 

Request for Admission No. 6a: 

The five single-judge election districts consist of 

eleven to fifteen parishes; the First Supreme Court District, 

the sole multi-member district, consists of four parishes and 

elects two judges. 



Answer to Request for Admission No. 6a: 

Paragraph 6a is admitted. 

Request for Admission No. 7a: 

The 1980 Census indicates that the population 

characteristics for the six supreme court elections districts are 

as follows: 

Total pop. Black pop. (%) Total VAP Black VAP (%)  

1 1,102,253 379,101 (34.39) 772,772 235,797 (30.51) 

2 582,223 188,490 (32.37) 403,575 118,882 (29.45) 

3 692,974 150,036 (21.65) 473,855 92,232 (19.46) 

4 410,850 134,534 (32.74) 280,656 81,361 (29.99) 

5 861,217 256,523 (29.79) 587,428 160,711 (27.36) 

6 556,383 129,557 (23.28) 337,510 78,660 (23.31) 

Answer to Request for Admission No. 7a: 

Paragraph 7a is admitted. 

Request for Admission No. 8a: 

The 1980 Census indicates that the population 

characteristics for the parishes in the First Supreme Court 

District [first district] are as follows: 



Parish  .Total pop.  

Jefferson 454,592 
Orleans 557,515 
Plaquemines 26,049 
St. Bernard 64,097 

Answer to Request for 

Black pop.(%) Total VAP Black VAP(%)  

63,001 (13.85) 
308,149 (55.27) 

5,540 (21.27) 
2,411 ( 3.76) 

Admission No. 8a: 

314,334 
397',183 
16,903 
44,352 

37,145 (11.81) 
193,886 (48.81) 
3,258 (19.27) 
1,508 ( 3.40) 

Paragraph 8a is admitted. 

Request for Admission No. 9a: 

As of July 1, 1988, registered voter data compiled by 

the Louisiana Commissioner of Elections indicated the following 

characteristics for the supreme court electric districts: 

District Total Regis. Voters  

2 
3 
4 
5 
6 

503,181 
278,084 
373,463 
209,348 
472,773 
310,018 

Black Regis. Voters (%)  

161,484 
73,907 
72,816 
59,933 

121,318 
71,435 

(32.09) 
(26.58) 
(19.50) 
(28.63) 
(25.66) 
(23.04) 

Answer . to Request for Admission No. 9a: 

Paragraph 9a is admitted. 

Request for Admission No. 10a: 

As of July 1, 1988, registered voter data complied by . 

the Louisiana Commissioner of Elections indicated the following 

characteristics for the first district: 



Parish Total Regis. Voters Black Regis. Voters (%)  

Jefferson 203,000 24,953 (12.29) 
Orleans 244,374 132,094 (54.05) 
Plaquemines 14,327 2,743 (19.15) 
St. Bernard 41 480 1,694 ( 4.08)  

Total 503,181 161,484 (32.09) 

Answer to Request for Admission No. 10a: 

Paragraph 10a is admitted. 

Request for Admission No. ha: 

There is a majority-vote requirement in election 

contests for the supreme court. 

Answer to Request for Admission No. ha: 

Paragraph ha is admitted. 

Request for Admission No. 12a: 

Elections for the two positions in the first district 

are not conducted in the same years (staggered terms). This 

precludes voters from single-shot voting. 

Answer to Request for Admission No. 12a: 

Paragraph 12a is admitted. 

Request for Admission No. 13a: 

Pursuant to state law, the Louisiana Supreme Court sits 

en banc and its jurisdiction extends statewide. 

Answer to Request for Admission No. 13a: 

Paragraph 13a is admitted. 



Request for Admission No. 14a: 

None of the members of the supreme court are elected on 

a statewide basis. 

Answer to Request for Admission No. 14a: 

Paragraph 14a is admitted. 

Request for Admission No. 15a.: 

No parish lines are cut by the supreme court districts. 

Answer to Request for Admission No. 15a: 

Paragraph 15a is admitted. 

Request for Admission No. 16a: 

The State of Louisiana's Constitutional Convention of 

1898 imposed a "grandfather" clause as well as educational and 

property qualifications for voter registration which were 

designed to limit black political participation. 

Answer to Request for Admission No. 16a: 

Paragraph 16a is denied. It was, however, designed to 

limit not only black political participation but also poor, white 

political participation. 

Request for Admission No. 17a: 

Within ten years of the new qualifications for voter 

registration authorized by the Convention of 1898, black voter 

registration had dropped from approximately 135, 000 persons in 

1896 to less than 1,000 persons in 1907. 



Answer to Request for Admission No. 17a: 

Paragraph 17a is denied. 

Request for Admission No. 18a: 

In 1921, the state amended its •constitution and 

replaced the "grandfather" clause with a requirement that an 

applicant "give a, reasonable interpretation" of any section of 

the federal or state constitution. The United States Supreme 

Court in United States v. State of Louisiana, 380 U.S. 145 (1965) 

held this "interpretation" test to be one facet of the state's 

successful plan to disenfranchise its black citizens. 

Answer to Request for Admission No. 18a: 

Paragraph 18a is admitted. 

Request for Admission No. 19a: 

In 1923, the state Democratic Party established, 

pursuant to state law, an all-white primary which was in use 

until 1944. 

Answer . to Request for Admission No. 19a: 

This paragraph cannot be admitted or denied. The best 

available information indicates that the white primary was 

established by law in 1906. 

Request for Admission No. 20a: 

Following the invalidation of the all-white primary in 

1944, the state adopted such electoral devices as citizenship 



tests, anti-single-shot laws and a majority vote requirement for 

party officers. 

Answer to Request for Admission No. 20a: 

Paragraph 20a is denied. These devices were instituted 

by democratic party rules. 

Request for Admission No. 21a: 

In 1972 two black candidates ran unsuccessfully for the 

supreme court from the first district. 

Answer to Request for Admission No. 21a: 

Paragraph 21a is admitted. 

Request for Admission No. 22a: 

No black person has been elected to the supreme court 

in the Twentieth Century. 

Answer to Request for Admission No. 22a: 

Paragraph 22 is admitted. 

Request for Admission No. 23a: 

No black person has run in a contested election for 

judicial office in any parish in the first supreme court district 

other than Orleans Parish. 

Answer to Request for Admission No. 23a: 

This statement is denied. Anderson Council, a black 

person, ran in the August 29, 1987 special primary for Jefferson 

Parish Juvenile Judge, Division A. 



Request for Admission No. 24a: 

The following list identifies all black persons who 

have been candidates in contested Orleans Parish judicial 

elections since 1978, the office they sought and the date of the 

election: 

Wilson Criminal Magistrate (September 16, 1978) 

Ortique Civil Dist. Ct. H 

Ortique Civil Dist. Ct. H 

Julien Civil Dist. Ct. I 
Wilson Civil Dist. Ct. I 

Julien Civil Dist. Ct. I 

Di Rosa Civil Dist. Ct. D 

Dorsey Civil Dist. Ct. F 
Johnson Civil Dist. Ct. I 
Douglas Civil Dist. Ct. B 
Dannell Juvenile Ct. Div. 
Gray Juvenile Ct. Div. 
Young Juvenile Ct. Div. 

A 
A 

Douglas Civil Dist. Ct. B 
Young Juvenile Ct. Div. C 

Magee Civil Dist. Ct. F 
Wilkerson Civil Dist. Ct. F 

Magee 

McConduit 

Douglas 

Hughes 

Hughes 

Civil Dist. Ct. F 

Municipal Court 

4th Cir. Court of 
Appeals, Dist. 1 

Civil Dist. Ct. G 

Civil Dist. Ct. G 

(March 3, 1979, primary) 

(April 7, 1979, general) 

(February 6, 1982, primary) 

(March 20, 1982, general) 

(June 18, 1983) 

(September 29, 1984, primary) 

(November 6, 1984, general) 

(February 1, 1986, primary) 

(March 1, 1986, general) 

(September 26, 1986, primary) 

(October 24, 1987) 

(March 8, 1987, primary) 

(April 16, 1988, general) 



• 

Answer to Request for Admission No. 24a: 

Paragraph 24a is denied. Omitted black candidates, the 

office they sought and the date of the election are: 

Douglas 
Young 
Young 
Pharr 
Young 
Young 

Young 
Thomas 
Blanchard 
Julien 
Dannel 
Hughes 

Juvenile Ct. Div. B (Sept. 16, 1978, primary) 
Juvenile Ct. Div. B (Sept. 16, 1978, primary) 
Juvenile Ct. Div. E (Oct. 17, 1979, primary) 
First City Ct. Div. C (Oct 27, 1979, primary) 
Juvenile Ct. Div. E (Dec. 8, 1979, general) 
First City Ct. Div. A 

First City Ct. 
First City Ct. 
Criminal Dist. 
Municipal Ct. 
Traffic Ct. 
Traffic Ct. 

(Sept. 13, 1980, primary) 
Div. A (Nov. 4, 1980, general) 
Div. C (Oct. 17, 1981, primary) 
Ct. J (Feb. 1, 1986, primary) 

(Oct. 1-, 1988, primary) 
(Oct. 1, 1988, primary) 
(Oct. 1, 1988, primary) 

Also Davis not DiRosa (DiRosa is white) was the candidate for 

Civil District Ct. D on June 18, 1983. Also Gray not Young was 

the candidate for Juvenile Ct. Div. A on November 6, 1984. Also 

Dannel not Lagarde was the candidate for Juvenile Ct. Div. D on 

September 27, 1986. Finally, the candidacies of Julien and 

Wilson in 1982 were for Criminal District Ct. I and the candidacy 

of Douglas in 1984 was for Criminal District Ct. B. 

Request for Admission No. 25a: 

There have been thirteen elections for district 

judgeship in Orleans Parish which featured a contest between a 

white and a black candidate since 1978. Black candidates have 

won three of the contests. In this same time period (1978 to the 

present), there have been thirteen elections for parochial or 



municipal judgeship positions which also have featured a contest 

between a white and a black candidate. Black candidates have won 

three of these elections. 

Answer to Request for Admission No. 25a: 

This statement is denied. There have been fifteen not 

thirteen elections for district judgeships in Orleans which 

featured a contest between a white and black candidate since 

1978. Black candidates have won eight of them. There have also 

been fifteen such elections for 15arochial or municipal judgeships 

in the same time period. Black candidates have won seven of 

those elections. 

Request for Admission No. 26a: 

The court of appeals in Orleans Parish elects eight 

judges on a parish-wide basis with a numbered-post provision-to a 

separate district of one of the appellate circuits. The only 

contested court of appeals election involving a black candidate 

was in 1987 when a black candidate was defeated in Orleans 

Parish. 

Answer to Request for Admission No. 26a: 

Paragraph 16a is admitted. 

Request for Admission No. 27a: 

Ernest Morial became the first black person to serve on 

a court of appeals in this century when he ran unopposed in 1972. 



Israel Augustine also was unopposed in 1974, as was Joan 

Armstrong in 1984. 

Answer to Request for Admission No. 27a: 

This statement is denied. Ernest Morial became the 

first black person to serve on a court of appeals in this century 

when he was elected in 1972 in a contested race against a white 

candidate. Mr. Morial received 80,663 votes in the November 7, 

1972 general election, while his opponent Oliver J. Delery 

received 52, 077 vote. Israel Augustine was unopposed in his 

election to the court of appeals in 1981, as was Joan Armstrong 

in 1984. 

Request for Admission No. 28a: 

A regression analysis of the twenty-seven judicial 

elections contests identified in Requests 24a to 26a indicates 

that black voters cast a majority of their votes for the black 

candidate (s) in twenty-four of the contests. The regression 

estimates reveal that in only four of these twenty-four instances 

did the black candidates receive less than 60% of the votes cast 

by black voters and in fifteen, over half of the elections 

analyzed, the black candidate received over 75% of the votes cast 

by black voters. In no election, however, did a majority of 

white voters vote for the black candidate(s). According to the 

regression estimates, less than 10% of the white voters voted for 



the black candidate in thirteen of the contests, an examination 

of these elections under an extreme case analysis indicates a 

similar result. 

Answer to Request for Admission No. 28a: 

Paragraph 28a cannot be affirmed or denied. As stated 

above, statements 24a and 25a are denied. Furthermore, 

defendant's expert has not completed the analyses of all these 

elections, and hence defendants cannot comment on the validity of 

this statement. 

Request for Admission No. 29a: 

Judicial election contests constituted one-third .(13 of 

39) of the elections analyzed by a panel of this court in Major 

v. Treen, 574 F. Supp 325 (E.D. La. 1983). 

Answer to Request for Admission No. 29a: 

The case of Major v. Treen, 574 F.Supp 325 (E.D. La. 

1983) held that judicial election contests constituted one-third 

(13/39) of elections analyzed by a panel of this court. It, 

however, failed to set forth the reasons therefor, and, 

therefore, to the extent of the factual reasons given, this 

statement of fact is denied. 

Request for Admission No. 30a: 

The white population in the parishes surrounding 

Orleans Parish, some of whom consist of persons seeking to avoid 



court-ordered school desegregation, are less receptive to 

candidacies by black person than are residents of Orleans Parish. 

Answer to Request for Admission No. 30a: 

Paragraph 30a cannot be affirmed or denied, since 

analyses have not been completed by defendant's expert to provide 

an answer to this statement. Part of the statement can never be 

answered as no data exist on the current attitudes of whites in 

those parishes on court-ordered school desegregation. 

Request for Admission No. 31a: 

The First Supreme Court District has twice the 

population of any congressional district in Louisiana and, in 

terms of population, is the largest of any of the state's 

election districts. 

Answer to Request for Admission No. 31a: 

Paragraph 31a is admitted. 

Request for Admission No. 32a: 

After 1954, school boards in Louisiana failed to 

abolish de jure segregation in the public schools voluntarily and 

it was necessary for local federal courts to issue decrees in 

order to obtain compliance with federal law. 



• 

Answer to Request for Admission No. 32a: 

Paragraph 32a is denied. Not all school boards in 

Louisiana resisted public school desegregation and it was not 

necessary for the federal courts to issue decrees for all school 

boards. 

Request for Admission No. 33a: 

The state maintained a dual university system until 

1981. 

Answer to Request for Admission No. 33a: 

Paragraph 33a is admitted. 

Request for Admission No. 34a: 

Public accommodations and facilities were not open to 

members of both races until the late 1960s. 

Answer to Request for Admission No. 34a: 

Paragraph 34a is denied. Some were open and some were 

not. It is likely that substantially more were not open than 

those that were open. 



Request for Admission No. 35a: 

The following 1980 Census statistics indicate that 

black residents of the four parishes in the first district lag 

significantly behind white residents in several socio-economic 

categories. 

Jefferson Orleans Plaquemines St. Bernard 

persons over 25 high 

. school grad. (%) 70.9 49.2 70.8 46.9 56.0 27.1 . 58.5 32.0 

per capita income $8,302 4,279 9,781 3,985 6,620 3,185 6,660 3,155 

families below 

poverty level (%) 5.3 24.7 7.4 33.4 7.7 32.4 6.6 31.6 

persons 200% below 

poverty level (%) 20.2 55.0 8.0 29.1 29.9 68.0 26.1 74.8 

% of civilian work-

force unemployed 3.6 8.3 4.0 10.1 3.5 14.4 4.7 15.0 

Answer to Request for Admission No. 35a: 

Paragraph 35a is admitted. 

Request for Admission No. 36a: 

A consistent application of the state policy of 

electing members of the supreme court form single-judge election 

districts that do not cross parish lines would result in Orleans 

Parish constituting a single-judge election district. 



Answer to Request for Admission No. 36a: 

Paragraph 36a is denied. Orleans Parish has too few 

persons to constitute a single-judge election district for the 

Louisiana Supreme Court. 

Request for Admission No. 37a: 

A supreme court election district comprised exclusively 

of Orleans Parish would have a black majority of the total 

pOpulation (55.27%) and of the registered voters (54.05%). 

Answer to Request for Admission No. 37a: 

Paragraph 37a is admitted. 

RORP G. PUGH 
Of the Law Firm of 

PUGH and PUGH 
Suite 1200 

330 Marshall Street 
Shreveport, Louisiana 71101-3051 

(318) 227-2270 

_ATTORNEYS FOR THE DEFENDANTS 



IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF LOUISIANA 

RONALD CHISOM, et al., 

Plaintiffs, 

UNITED STATES OF AMERICA, 

Plaintiff-intervenor, 

versus 

CHARLES E. ROEMER, et al., 

Defendants. 

DEFENDANTS' ANSWERS TO UNITED STATES' FIRST  
SET OF INTERROGATORIES  

Now into Court, through undersigned counsel come the 

defendants, CHARLES E. "BUDDY" ROEMER, in his capacity as 

: CIVIL ACTION NO. 
: 86-4075 

: Section A 

Governor of the State of Louisiana; FOX McKEITHEN, in his 

capacity as Secretary of State of Louisiana; and JERRY M. FOWLER, 

in his capacity as Commissioner of Elections of the State of 

Louisiana, who, for their answers to the United States' First Set 

of Interrogatories, show: 

Interrogatory No. 1: 

If the defendants deny, in whole or in part, any item in the 

United State First Set of Requests for Admission, for each such 

request, 

(a) Set out the number of the request 



(b) State the specific grounds for the denial. 

Answer to Interrogatory No. 1: 

Interrogatory No. 1 is answered within the answers to 

the Requests for Admission. 

Interrogatory No. 2: 

State whether from 1922 to the present time any proposals 

have been introduced in the Louisiana Legislature either to 

modify the districts from which members of the state supreme 

court are elected or to alter the method in which they are 

selected. If so, for each proposal provide 

(a) A detailed description of the proposal; 

(b) The date the proposal was introduced; 

(c) The name and race of the sponsor(s); 

(d) The reason(s) for the rejection of the proposal. 

Answer to Interrogatory No. 2: 

In the last session of the Legislature several Bills 

were introduced in the Louisiana House relative to the selection 

of Supreme Court Justices, these Bills were House Bills 149, 637, 

and 1630. Copies of each of which are attached. They were all 

voted down in Committee without a specific announced reason being 

given by any of the members of the Committee for their ultimate 

vote. There was also one Bill introduced in the Senate, Senate 



Bill 65, a copy of this is also attached to these answers. This 

Bill fell four short of the number of votes necessary for its 

passage without there being an explanation by any of the Senators 

for their vote for or against. 

Interrogatory No. 3: 

Identify each state interest served by the inclusion of 

a multi-judge election district in the electoral scheme for 

electing members of the supreme court. 

Answer to -Interrogatory No. 3: 

Continuity, stability and custom. This electoral 

scheme was created 109 years ago and has successfully served the 

State's purposes from then until now and has been included in 

each of the State's Constitutions as adopted by the electorate, 

both black and white thereafter. 

ROBERT G. PUGH 
Of the Law Firm of 

PUGH and PUGH 
Suite 1200 

330 Marshall Street 
Shreveport, Louisiana. 71101-3051 

(318) 227-2270 

ATTORNEYS FOR THE DEFENDANTS 



I 
HLS 88-709 

Regular Session, 1988 

HOUSE BILL NO. 63 -7 

BY REPRESENTATIVE CARTER 

• 
ORIGINAL 

COURTS/SUPREME COURT: Provides for seven single-member districts to 
elect the justices of the Louisiana Supreme Court 

1 AN ACT 

2 To amend and .reenact R.S. 13:101, relative to supreme court 

3 districts, to provide for seven single-member districts, to 

4 proi/ide for the -parishes comprising the districts, and to • 

5 provide for related matters. 

6 Be it enacted by the Legislature of Louisiana: 

7 Section 1. R.S. 13:101 is hereby amended and reenacted to read 

8 as follows: 

9 §101. Supreme court district; justices 

10 A. The state shall be divided into 94* seven supreme court 

11 . districts, and the supreme court_ shall be composed of seven 

12 justices, fees *he ee44 d4e*p.iete one from each district as set 

13 forth below: 

14 (1) First district. The parishes of 0*-leeneT St. Bernard, 

15 Plaquemines, and Jefferson shall compose the first district. 

16 4*es wb4e4 we juoticca she44 be elected. 

17 (2) Second district. The parishes of Caddo, Bossier, 

18, Webster, Claiborne, Bienville, Natchitoches, Red River, DeSoto, 

19 Winn, Vernon, and Sabine shall compose the 'second district. 

20 fee, wit4e4 efte iee*-iee ehe44 be elected. 

21 (3) Third district. The parishes of Rapides, Grant, 

22 Avoyelles, Lafayette, Evangeline, Allen, Beauregard, Jefferson 

Page 1 of 3 

ORIGINAL 

CODING: Words in s**oe4 tb.peogb type are deletions from existing 
law; words underlined are additions. 



HLS 88-709 

1 Davis, Calcasieu, Cameron, and Acadia shall compose the third 

2 district. k*ee w414e4 efte justice sbe44 be elected. 

3 (4) Fourth district. The parishes of. Union, Lincoln, 

4 Jackson, Caldwell, Ouachita, Morehouse, Richland, Franklin, West 

5 Carroll, East Carroll, Madison, Tensas, Concordia, LaSalle, and 

6 

7 

8 

9 

Catahoula shall compose the fourth district. 4ftee wft4e4 efte 

juoticc choll be elected. 

(5) Fifth district. The parishes of East Baton Rouge, 

West Baton Rouge, West Feliciana, East Feliciana, St. Helena, 

10 Livingston, Tangipahoa, St. Tammany, Washington, Iberville, 

• 11 Pointe -Coupee, and St. Landry shall compose the fifth district. 

12 fEem w44e4 eee juoticc 94444 be elected. 

13 (6) Sixth district. The parishes of St. Martin, St. Mary, 

14 Iberia, Terrebonne, Lafourche, AsiUmption, Ascension, St. John 

15 the Baptist, St. James, St. Charles, and Vermilion shall 

16 compose the sixth district. 4.Fee wbieh one iftebiee ehe44 be 

17 . elected. 

18 (7) Seventh district. The parish of Orleans shall compose 

19 the seventh district.  

20 B. Each justice in office, on the effective date of this  

21 Section shall be the justice for the district described herein 

22 in which he resides and shall complete the term for which he was 

23 • elected. 

• 
Page 2 of 3 

ORIGINAL 

CODING: Words in bbpoeft bbreetb type are deletions from existing 
law; words underlined are additions. 



HLS 88-709 

DIGEST 

The digest printed below was prepared by House Legislative Services. 
It constitutes no part of the bill. 

Carter Act HB No. 

• Present law provides for six supreme court districts, from which 
seven justices are elected. Each district elects one justice except 
the 1st, which is composed of the parishes of Orleans, Jefferson, 
Plaquemines, and St. Bernard. 

Proposed law would provide for seven districts, each of which would 
elect one justice. The 1st district would be composed of Jefferson,. 
Plaquemines, and St. Bernard Parishes while the 7th district would be 
composed of Orleans Parish. Districts two through six would be 
unchanged from present law.  

(Amends R.S. 13:101) 

Page 3 of 3 

ORIGINAL 

CODING: Words in st*oe4 through type are deletions from existing 
law; words underlined are additions. 



HLS 88-388 

Regular Session, 1988' 

HOUSE BILL NO. /4(1 

BY REPRESENTATIVE C. R. JONES ORIGINAL 

COURTS/SUPREME COURT: Provides for seven single-member districts to 
elect the justices of the Louisiana Supreme Court 

AN ACT . 

2 To amend and reenact R.S. 13:191, relative to supreme court 

3 districts, to provide for seven single-Member districts, to 

4 provide for the parishes comprising the districts, and to 

5 provide for related matters. 

6 Be it enacted by the Legislature of Louisiana: 

7 Section 1. R.S. 13:101 is hereby amended and reenacted to read 

8 as follows: 

9 §101. Supreme court district; justices 

10 A. The state shall be divided into 04* seven supreme court 

11 districts,_ and the supreme court - shall be composed of Seven 

12 justices, 440m the 0044 d400e4000 one from eachAistrict as set 

13 forth below: 

14 (1) First district. The parishes of Orleans, St. Bernard, 

15 Plaquemines, and Jefferson shall compose the first district. 

16 4*em wh4eb twa juaticca sbe44 be elected. 

17 (2) Second district. The parishes of Caddo, Bossier, 

18 Webster, Claiborne, Bienville, Natchitoches, Red River, DeSoto, 

19 Winn, Vernon, and Sabine shall compose the second district. 

20 4-pem wh4e4 efte juatice 94044 be elected. 

21 (3) Third district. The parishes of Rapides, Grant, 

22 Avoyelles, Lafayette, Evangeline, Allen, Beauregard, Jefferson 

Page 1 of 3 

ORIGINAL 

CODING: Words in struck -W4-reugh type are deletions from existing 
law; words underlined are additions. 



HLS 88-388 

1 Davis, Calcasieu, Cameron, and Acadia shall compose the third 

2 district 4eem vh4eh one joeoiee ono44 be cleated. 

3 (4) Fourth district. The parishes of Union, Lincoln, 

4 Jackson, Caldwell, Ouachita, Morehouse, Richland, Franklin, West 

5 Carroll, East Carroll, Madison, Tensas, Concordia, LaSalle, and 

6 Catahoula shall compose the fourth district. 4eem wh4e4 ene 

7 aite44 be oleeeed, 

8 (5) Fifth district. The parishes of East Baton Rouge, 

9 West Baton Rouge, West Feliciana, East Feliciana, St. Helena, 

10 Livingston, Tangipahoa, St. Tammany, Washington, Iberville, 

11 Pointe Coupee, and St. Landry shall compose the fifth district. 

12 4eem wh4eh tone imee4ee ehe44 be e4emted, 

13 (6) Sixth district. The parishes of St. Martin, St. Mary, 

14 Iberia, Terrebonne, Lafourche, Assumption, Ascension, St. John 

15 the Baptist, St. James, St. Charles, and Vermilion shall compose 

16 the sixth district. 4eee wh4eh ene iee44ee ehe44 be elcotcd. 

17 (7) Seventh district. Tho_parish of Orleans shall compcYte 

18 the seventh district.  

19 B. Each justice in office on the effective date of this 

20 Section shall be the justice for the district described herein 

21 . in which he resides and shall.complete the term for which he was  

22 elected.  

DIGEST 

The digest printed below was prepared by House Legislative Services. 
It constitutes no part of the bill. 

C. R. Jones 
Act HB No. 

Present law provides for six supreme court districts, from which 
seven justices are elected. Each district elects one justice except 
the 1st, which is composed of the parishes of Orleans, Jefferson, 
Plaquemines, and St. Bernard. 

Proposed law would provide for seven districts, each of which would 
elect one justice. The 1st district would be composed of Jefferson, 

Page 2 of 3 

ORIGINAL 

CODING: Words in otpee4 44-ree-gli type are deletions from existing 
law; words underlined are additions. 

- 



HLS 88-388 
DIGEST 

Plaquemines, and St. Bernard Parishes while the 7th district would be 
composed of Orleans Parish. Districts two through six would be 
unchanged from present law.  

(Amends R.S. 13:101) 

Page 3 of 3 

ORIGINAL 



• 
HLS 88-1924 

Regular Session, 1988 

HOUSE BILL NO. 

REPRESENTATIVE BRUNEAU 

• • 
ORIGINAL 

COURTS/SUPREME COURT: Creates seven single-member districts for the 
supreme court 

1 AN ACT 

2 To enact R.S. 13:101.1 and to repeal R.S. 13:101, relative to the 

3 ' districts of the supreme court, to provide for seven districts, to 

4 provide that one justice be elected from each district, to provide 

5 for the terms of justices presently serving, to provide for filling 

6 of vacancies, to provide for the effective date of repeal, and to 

7 provide for related matters. 

8 Be it enacted by the Legislature of Louisiana: 

9 Section 1. R.S. 13:101.1 is hereby enacted to read as follows: 

10 §101.1. Supreme court district; justices  

11 A. The state shall be divided. into seven supreme court  

12 districts, and the supreme court' shall be composed of one 

13 justice from each of the said districts as set forth below:  

14 Cl) First district. The first district is composed of 

15 that portion of Orleans Parish designated as Wards 1, 2, 9, 10,  

16 11, 12, 13, 14, 15 and 16; Precincts 1, 3, 3A; 4, 5, 6, 7, 8, 9,  

17 10, 12, 13, 14, 15, and 16 of Ward 3; Precincts 2, 3, and 4 of  

18 Ward 4; Precincts 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, and 11 of Ward  

19 5; Precincts 1, 2, 4, 5, 6, and 7 of Ward 6; Precincts 1, 2, 4,  

20 4A, 5, 6, 7, 8, 9, 9A, 10, 11, 12, 13, 14, 15, 16, 17, 17A, 18,  

21 19, 20, 20A, 21, 22, 23, 24, 25, 26, 26A, 27, 27A, 27B, 28, 28A,  

22 29, 30, 31, 33, 34, and 35 of Ward 7; Precincts 1, 2, 4, 5, 6,  

Page 1 of 7 

ORIGINAL 

CODING: Words in s*.kie.ik *.ii-remth type are deletions from existing law; 
words underlined are additions. 



HLS 88-1924 

1 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23,  

2 24, 25, 25A, 26A, 27A, and 30 of Ward 8; Precincts 1, 2, 3, 4,  

3 5, 6, 7, 8, 9, 10, 11, 12, 13, 13A, 14, 15, and 16 of Ward 17;  

4 Plaquemines Parish; and St. Bernard Parish.  

5 (2) Second district. The second district is composed of 

6 that portion of Orleans Parish designated as Precincts 17, 18,  

7 19, and 20 of Ward 3_; Precincts 5, 6, 7, 8, 9, 10, 10A, 11, 12,  

8 13, 13A, 14, 14A, 15, 16, 16A, 17, 17A, 18, 18A, 19, 20, 20A,  

9 21, 21A, 22, and 23 of Ward 4; Precincts 12, 13, 14, 15, 16, 17,  

10 18, and 19 of Ward 5; Precincts 8 and 9 of Ward 6; Precincts  

11 32, 33A, 36, 36A, 37, 38, 38A, 39, 40, 41, and 42 of Ward 7;  

12 Precincts 26, 27, 28, and 29 of Ward 8; Precincts 17, 18,18A,  

13 19, 19A, 20, and 21 of Ward 17; Jefferson Parish; and St.  

14 Tammany Parish.  

15 (3) Third district. The third district is composed of 

16 Acadia Parish; Allen Parish; . Beauregard Parish; Calcasieu 

17 Parish; Cameron Parish; Evangeline Parish; Jefferson Davis  

18 Parish; Lafayette Parish; and St. Landry Parish.  

19 (4) Fourth district. The fourth district is composed of 

20 Avoyelles Parish; Caldwell Parish; Catahoula Parish; Concordia 

21 Parish; East Carroll Parish; Franklin Parish; Grant Parish;  

22 JaCkson Parish; LaSalli Parish; -Lincoln Parish; Madison Parish;  

23 Morehouse Parish; Ouachita Parish; Rapides Parish; Richland  

24 Parish; Tensas Parish; Union Parish; and West Carroll Parish.  

25 (5) Fifth district. The fifth district is composed of East  

26 Baton Rouge Parish; East Feliciana Parish; Livingston Parish;  

27 St. Helena Parish; Tangipahoa Parish; Washington Parish; West 

28 Baton Rouge Parish; and West Feliciana Parish.  

29 (6) Sixth district. The sixth district is composed of 

30 Ascension Parish; Assumption Parish; Iberia Parish; Iberville 

31 Parish; Lafourche Parish; Pointe Coupee Parish; St. Charles  

32 Parish; St. James Parish; St. John the Baptist Parish; St.  

Page 2 of 7 

ORIGINAL 

CODING: Words in et-Fee-It t.41-Fe4igli type are deletions from existing 
law; words underlined are additions. 



}(LS 88-1924 

1 Martin Parish; St. Mary Parish; Teriebonne Parish; and Vermilion 

2 Parish.  

3 (7) Seventh district. The seventh district is composed of 

4 Bienville Parish; Bossier Parish; Caddo Parish; Claiborne  

5 Parish; DeSoto Parish; Natchitoches Parish; Red River Parish;  

6 Sabine Parish; Vernon Parish; Webster Parish; and Winn Parish.  

7 B. Each justice in office on the effective date of this  

8 Section shall be the justice for the district described herein  

9 in which he resides and shall complete the term for which he was  

10 elected.  

11 C. The successors of the justices in office on the 

12 effective date of this Section shall be elected from the 

13 following districts in the year designated:  

14 (1) The first district in 1990.  

15 (2) The seconddistrict in 1988.  

16 (3) The third district in 1996.  

17 (4) The fourth district in 1996.  

18 (5) The fifth district in 1988.  

19 (6) The sixth district in 1992.  

20 (7) The seventh district in 1994.  

21 D. A vacancy in the office of justice of the supreme court  

22 which is filled after the effective date of this Section shall  

23 be filled for the remainder of the term, as provided by law,  

24 from the district described herein which, by reason of such  

25 vacancy, is without a justice.  

26 E. The supreme court districts established in R.S. 13:101  

27 shall remain effective for the limited purpose of the completion 

28 of the terms of the justices elected therefrom who are in office  

29 on the effective date of this Section until a successor to each 

30 justice in office on the effective date of this Section has been 

31 elected from the districts described herein, either by reason of 

Page 3 of 7 

ORIGINAL 

CODING: Words in s-t-F-tiel t4Foug4 type are deletions from existing 
law; words underlined are additions. 



• HLS 88-1924 
• 

1 a vacancy in office or as specified in Subsection C of this 

2 Section.  

3 Section 2. With respect to any precinct enumerated in this Act 

4 which has been subdivided by action of any parish governing authority 

5 or registrar of voters on a nongeographic basis, the enumeration 

6 herein of the general precinct designation shall be construed to 

7 include all polling subdivisions thereof irrespective of the 

8 designation of such subdivisions by a parish governing authority or 

9 registrar of voters. 

10 Section 3. The wards and precincts referred to in this Act are 

11 those existing as of January 1, 1980. 

12 Section 4. The effectiveness of this Act shall not reduce the 

13 term of office of any justice of the supreme court holding office on 

14 the effective date of this Act. 

15 . Section 5. R.S. 13:101 is repealed, effective- at noon on 

16 January 1, 1997. 

DIGEST 

The digest printed below was prepared by House Legislative Services. 
It constitutes no part of the bill. 

Bruneau 
Act HB No. 

Present law divides the state into six supreme court districts. 
Provides that two justices are elected from the metropolitan district 
including Orleans, Jefferson, Plaquemines, and St. Bernard Parishes; 
and one justice is elected from each of the other five districts. 

Proposed law redraws the six state supreme court districts into seven 
districts, each electing one justice. 

District changes are as follows: 

Orleans/Jefferson area 

Present district 1 elects two justices. District includes the 
parishes of Orleans, St. Bernard, Plaquemines, and Jefferson. 

Proposed district 1 elects 1 justice. District includes: 
Plaquemines 
St. Bernard 

Orleans, Wards 1, 2, 9, 10, 11, 12, 13, 14, 15 and 16 

Page 4 of 7 

ORIGINAL 

CODING: Words in 54-rtre4 t-h-Fough type are deletions from existing 
law; words underlined are additions. 



• 

HLS 88-1924 
DIGEST 

Ward 3, pcts. 1, 3, 3A, 4, 5, 6, 7, 8, 9, 10, 12, 13, 
14, 15, and 16 

Ward 4, pcts. 2, 3, 4 

Ward 5, pcts. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11 
Ward 6, pcts. 1, 2, 4, 5, 6, 7 

Ward 7, pcts. 1, 2, 4, 4A, 5, 6, 7, 8, 9, 9A, 

10, 11, 12, 13, 14, 15, 16, 17, 17A, 18, 19, 20, 20A 

21, 22, 23, 24, 25, 26, 26A, 27, 27A, 27B, 28, 28A, 29, 
30, 31, 33, 34, 35 

Ward 8, pcts. 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 

13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 
25, 25A, 26A, 27A, 30 

Ward 17, pcts. 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 
11, 12, 13, 13A, 14, 15, and 16, 

Proposed District 1 population: 596,658 

Proposed district 2 elects one justice. District includes: 
Jefferson 
St. Tammany 

Orleans, Ward 3, pcts. 17, 18, 19, 20 

Ward 4, pcts. 5, 6, 7, 8, 9, 10, 10A, 11, 12, 13, 
13A, 14, 14A, 15, 16, 16A, 17, 17A, 18, 

18A, 19, 20, 20A, 21, 21A, 22, 23 
Ward 5, pcts. 12, 13, 14, 15, 16, 17, 

18, 19 . 
Ward 6, pcts. 8, 9 

Ward 7, pcts. 32, 33A, 36, 36A, 37, 38, 38A, 
39, 40, 41, 42 

Ward 8, pcts. 26, 27, 28, 29,, 

Ward 17, pcts. 17, 18, 18A, 19, 19A, 20, 21 

Proposed District 2 population: 616,116 

District 3 

Present district 3 includes the parishes of Rapides, Grant, 
Avoyelles, Lafayette, Evangeline, Allen, Beauregard, Jefferson Davis, 
Calcasieu, Cameron, and Acadia. 

Proposed district 3 includes the parishes of Lafayette, Evangeline, 
Allen, Beauregard, Jefferson Davis, Calcasieu, Cameron, Acadia, and 
St. Landry. 

Proposed District 3 population: 583,549 

District 4 

Present district 4 includes the parishes of Union, Lincoln, Jackson, 
Caldwell, Ouachita, Morehouse, Richland, Franklin, West Carroll, East 
Carroll, Madison, Tensas, Concordia, LaSalle, and Catahoula. 

Proposed district 4 includes the parishes of Union, Lincoln, Jackson, 
Caldwell, Ouachita, Morehouse, Richland, Franklin, West Carroll, East 
Carroll, Madison, Tensas, Concordia, LaSalle, Catahoula, Rapides, 
Avoyelles, and Grant. 

Proposed District 4 population: 602,986 

District 5 

Present district 5 includes the parishes of East Baton Rouge, West 
Baton Rouge, West Feliciana, East Feliciana, St. Helena, Livingston, 
Tangipahoa, St. Tammany, Washington, Iberville, Pointe Coupee, and 
St. Landry. 

Page 5 of 7 

ORIGINAL 



- f HLS 88-1924 
DIGEST 

Proposed district 5 includes the parishes of East Baton Rouge, West 
Feliciana, East Feliciana, St. Helena, Livingston, Tangipahoa, 
Washington, and West Baton Rouge. 

Proposed District 5 population: 609,838 

District 6 

Present district 6 includes the parishes of St. Martin, St. Mary, 
Iberia, Terrebonne, Lafourche, Assumption, Ascension, St. John the 
Baptist, St. James, St. Charles, and Vermilion. 

Proposed district 6 includes St. Martin, St. Mary, Iberia, 
Terrebonne, Lafourche, Assumption, Ascension, St. John the Baptist, 
St. James, St. Charles, Vermilion, Iberville, and Pointe Coupee. 

Proposed District 6 population: 612,729 

Northwest Louisiana 

Present district 2 includes the parishes of Caddo, Bossier, Webster, 
Claiborne, Bienville, Natchitoches, Red River, DeSoto, Wihn, Vernon, 
and Szbine. 

Proposed district 7 includes all of present district 2. 

Proposed District 7 population: 582,096 

Proposed law provides that each justice in office on the effective 
date of the Act shall be the justice for the district described in 
proposed law in which he resides. Provides that each such justice 
shall complete the term for which he was elected. Further provides 
that the successors to such justices shall be elected from the 
following proposed law districts in the following years: 

District 1 in 1990 

District 2 in 1988 
District 3 in 1996 . 
District 4 in 1996 
District S in 1988 
District 6 in 1992 
District 7 in 1994 

Proposed law provides that any vacancy in office occurring before the 
regular election dates specified above shall be filled from the 
district in proposed law which is without a justice by reason of such 
vacancy. 

Proposed law provides that present law districts remain effective for 
the purpose of the completion of the terms of the justices elected 
from them or until a vacancy in office occurs. Proposed law repeals 

present law which creates present districts effective noon, January 
1, 1997. 

Proposed law specifies that, if precincts listed in district 
descriptions have been subdivided for purposes of polling, the 
listing of the general precinct designation includes all such polling 
subdivisions of such precincts. Also specifies that all wards and 
precincts referenced in proposed law are those existing on January 1, 
1980. 

Proposed law district populations as shown on this digest are all 

within plus or minus five percent of the "ideal" district population. 

The "ideal" district population, determined by dividing the state 

Page 6 of 7 

ORIGINAL 



• 

HIS 88-1924 
DIGEST 

population of 4,203,972 by seven (the number of districts),. is 
600,567. 

Population counts in this digest are derived from Census of 
Population and Housing, 1980; P.L. 94-171 Population Counts/Prepared 
by the Bureau of the Census, Washington, D.C.: 1981, as validated and 
adjusted by Louisiana House of Representatives staff; Louisiana 
Senate staff, and Division of Research Services, Louisiana State 
University, 1981. Population data and statistical information are 
supplied herein for purposes of information and analysis and form no 
part of the actual text of the bill. 

. (Adds R.S. 13:101.1; Repeals R.S. 13:101) 

Page 7 of 7 

ORIGINAL 



rs aga 20:4: LA. scls:.7( scm-34z-Ele-99 • F.Z 23 

IRS 18-341 

1 Regular Session, 1918 

2 SENATE BILL NO. 15 

3 BY MR. HA1NKEL 

4 

5 

6 

7 

ENGROSSED 

9 JUDGES. Constitutional amendment to provide a merit selection/retention system 
for judges of the supreme court, court of appeal, and district, family, and juvenile 

10 courts. 

11 

12 

13 

14 

15 

16 A JOINT RESOLUTION 

17 Proposing to add Article V, Sections 22(D), (E), (F), and (G) of the Constitution of 

18 Louisiana, relative to judges; to provide for merit selection and merit 

19 retention of judges of the supreme court, court of appeal and district, 

20 family, and juvenile court; to create nominating commissions for nominating 

21 persons under a merit selection system for judges and to provide for its 

22 powers, duties, and functions; to require that the commission in a merit 

23 selection system propose nominees for each office of judge from which the 

24 governor will select one as judge; to provide for selection by the supreme 

25 court if the governor fails to select a judge; to provide for merit retention 

26 election to create a judicial nominating commission selection board and 

27 provide for its powers, duties, and functions; to provide for a transition for 

28 incumbent judges; and to specify an election date for submission of the 

29 proposition to electors and provide a ballot proposition. 

30 Section 1. Be it resolved by the Legislature of Louisiana, two-thirds of the 

31 members elected to each house concurring, that there attal/ be submitted to the 

32 electors of the state of Louisiana, for their approval or rejection in the manner 

33 provided by law, a proposal to add Article V, Sections 22(D), (E), (F), and (G) of the 

34 Constitution of Louisiana, to read as follows 

35 922. Judges; Election; Vacancy; Merit Selection and Merit Retention 

Page 1 

CODING: WQrds in streeir-throegh type are deletions from existing law; 
words imderscoeed and boldface4 are additions. 



• 

- t.•:•• • ..; 4.; '' 
.. .,. .... I . • . • ..„,, • .t - : ;., .• • •••,. • • "r• ,•. 

I 4. 

• . . t • :... V. " 4  • in , . ..4I ......**‘. . .;:l.: • . . 1  

.. 1: 

iR511-341 i . , ,. •.,...4 ...1.... ..7; •-?*.: 
,.." t .1: -- - • . 

• • 

• ; i:.1 ,f• • • .• 
: .1,-:.1*;;!, • 
; :• • •Frii ' • 

• . -•;.* • 
• • • .4 

. • ...I,-
. • 

• 

: . 

• 

u; • 
t4 /* 

• • • 5:11 

• • • • • • 4‘. :APd•j • .: 

SeW 

• 

(D) ii,aili.sibletiost. (1) /krintilist oh kniiiry 1, 1,19, a newly-created 
. • • . 6 .. 
• . A : judgeibIP or I vacancy in the Attlee of jiisike 61 tie supreme court, judge of 

'-%•.;"- .-.-.- • -:-..* ;,b1, •• 6 
• .-..1. ,::..:„. . tie court of.appeili or judge of 1 ehitiled NA* Ind juvenile court shall be . .... . .. . . -....*-- • : - 4-

-, ...:,.:;(, ;-:•-• : f . . . filled under a ayitein of merit ikliatkii if jUdrel as provided in this 

•:-..•-•••!',1.•••• .---' 1...11. .. • tiaragraph. • 
.-'.? ;.... '-`-i...*; ••• - •*-: • 
- • . .:•S!' :... • • • ... .. . - ... t • . • 4. . 

M.. A ,jvciicis. iominitint .eoaiiiiiiiiitikat .nomtnite two or three . . , 
-, ii-e.--....-.. • • -441:! ..vet -?: - . , yl t; .0. r; • : " • ,.. 

*.....f,..4....-x ... . ' - persona for .iiiii newly-created JudgeOlp,.iliainiey. The governor shall 

need:aka submitted by the 

..ioallni.t.ig tin.: ni... 01#1.6i1... lb fill the Isii4iiii4110 hdgeship or vacancy on the • • . • . 

• ii/preme ect•bi ‘POil; * diStiiii; Iiiiiiii rind Juvenile court. If the • • • •.. :,. :.- . • • • : . ••• 

• Salieti the Z.onsent of the Senate; • &E• • 

45 

, . ...• 
-17'• -• • -- 1St •fi'10•4;. - 4 .1 -;• - 10 ,  

0.- f..-; . .4 Merit .seliletIon of Judges 

shall serve an Initial. term is follows...:17pon eipirition Of, two years service as 

4:x•taz.16110,e, such ilege..04 40. Oubjett.taljiler11,iDeteiiiindjitiOetiOh to be held at • . . : 

ç2eititii4kilithilligitIMW irnti.ikkOtillted, shill serve 
. • "..4.;._••A.;-•.. •• • —,,174,".••• • , 

44:104.414iiiteiCNOt14031t! " 444011.1164Odgeshlp and, 
.2-• • . 

c•laithereal j èbJ to 

•,. .. • 
•24 .• 2-::, proVidad me..r. 11)10. lfietirAIt • Li 

. • 

25 . (4) No person who fails .to receiVe .2*.411 

26 
••▪ • . 

governor filig li. se1if in of tbi.flhès iilthln sixty days after 

submission .or the ni.:.ini!ned 4 'tie ealisailsekiii, then a majority vote of the 

••• *Primi ennit..1*.#14FtinAiitittie.4016.ii Co serve as judge from the list 

Pirit.htfht 1611 .6 r judges 

election as provided in Paragreph (E)..siall. Jo; -flOcaliikflia..)11;d1 --..judibtaln; 

-ii ,.. -_:,..,„ nominating commission for the subsequent ..(insi;eililit fiiiiktb4.tiffIL4 of 13 
7 ...e. &•iii.: •••• • ••-• •• . ; • : • 1: • ,,:t:1 • - .'• '•• ' "• ••• • - • :816 
- ••:•-•'• • ••••• : 28 al.: i-; -.judge.. :, • . ••• • • .: - - : . : at .f.:;•,..*-,..•:)11.-itt.••;4 
•-0 4 ia ' ". A ..„ • ., . ... .. , .._ . ,: •., . ety 

. .... . - ‘7 ' .!... " . "nide VI Section rifg) is ill proposed Deii lawi_lik;;;44;:;;;:iiii...4:i.liQ6i4. - • ,. _ . !..,.. r.,,,,. , -14.-.-• . ..., . ...: .:::.,. 
'4.Z! ..... -A.:::1 :....:;•;$9 iiii.:..4..ii,i, i:,et . .4eitt .1tetSntloii. BeginnIng.iii-;inuarsiliffitiic:,•.!thi'I011owing - • ..-......•,... • .4- 

• ..!. l  ,-;•••....1/..:;: - . . . .• . :..•••• 1 .- ' _ • .. - . • •. : : .. 

...t..... ./.....r.:. • .9j;:a. sihr.s.p.l. it oil ktjit srefiritloti • for Judges .datiilL .1iipry • Iii! &veil :.supre Me Court --
• .:•-•.-.'-..! ....1.••:•. '. ••• ...•....:..:..--; .• • ' - -.•••: • 

'-.';:•. - ..: -;',•7; .-.• • 32 il,-.±..•.:$1.1stijOi...ce0i, if ..appeal :Irciiii, iind:,.diiiiial; faintiy, itid Juvenile court 
!.-,'.. :-. • : 'f, ..;:• • • %.- ..'. - : '• . 1 .'. .. . . . 
.-.-:,):-! ••.,:.::' ' . 33 ,4q- •-„, t:liidiciii.i. dIst;lit ,:Not; len than ninety. tiiys -prioi••••to kfie holding of the nest 

34 regular congressional primary election preceding the expiration of his term of 

• 

35 office each Justice of the supreme court, judge of a ociurt of appeal, or judge 

- -Page! • . 

CODING: Words in seTweir-thivogit type are .delitIOna.3 f'r om ixiitIng law; 
words Lnderscored and boldfaced are additions. •- • ' • 

•-;31 

7-aa 

4;. 



r1-4 , •Ect le•41‘ (k. SC t4.11. 504 - -8895. F.3 .13 

• 
US 11-341 

1 
of a district, family, or juvenile court, may file, with the secretary of state, 

2 a declaration of eandidsey for election to succeed himself in the office of 

3 justice or judge. If the deelsratIon of candidacy is not filed by a justice or 

4 judge, a vacancy shall result upon expiration of his term of office which shall 

be filled under the system of merit selection of judges as provided in 

6 Paragraph D of this Section. Upon filing a declaration of candidacy, the 

7 secretary of state shall cause to be included on the ballot for submission to 

the voters in the respective supreme court district, court of appeal circuit, or 

9 judicial dlitrict at the next regular congressional primary election the 

10 question of retention of the particular justice or judge in the same judgeship. 

11 If a majority of those voting on the question vote for retaining the judge in 

12 office, then at the expiration of his term of office, he shall be deemed to 

13 have beep elected for another term of office. If a majority of those voting 

14 on the-question vote against retaining the judge in office, upon expiration of 

15 his term fa office, a vacancy shall exist In that office which shall be filled in 

16 accordance with the provisions of Paragraph (D). 

17 Article V, Section 22(1") is all.projioaed new law. 

18 (P) Nominating Commissions. The judicial nominating commission 

19 selection board and each nominating commission shall reflect substantially 

20 the racial and minority characteristics of the population of the respective 

21 supreme court district, court of appeal circuit, and judicial district without 

22 compromising the over-riding goal of achieving consistent excellence in the 

23 judiciary. 

24 (1X4 The judicial nominating commission selection board shall be 

25 composed of three members from each court of appeal circuit and shall be 

26 selected u provided in this Subparagraph. 

27 (b) Those members of the legislature whose legislative district is 

28 included, in whole or in part, within the territorial jurisdiction of each court 

29 of awe') circuit shall select, by majority vote, throe persons domiciled in the 

30 circuit to Serve on the judicial nominating commission selection board from a 

31 list of nominees submitted by such professional and civic groups or 

32 organizations as may be determined by the legislature. The legislature shall 

33 provide by law for submission of nominees from specific professional and 

34 civic group or organizations under the provisions of this Paragraph. 

35 (2) The following nominating commissions shall exist: 

Page 3 

CODING: Words in struele-through type are deletions from existing law; 
words underscored and boldfaced are additions. 



- P.0 Al 

• 1188 11-341 • 

1 (a) Supreme Court Nominating Commission. The supreme court 

2 nominating commission shall be composed of five Standing members selected 

3 as follows: the chairman of each court of appeal nominating commission shall 

4 select a member from his respective commission to serve as one of the 

standing members on the supreme court nominating commission; the selection 

6 of the five standing members shall be done in such a manner that the standing 

7 members of the commission shall be composed of two persons licensed to 

8 practice law in this state and three persons who are not licensed to practice 

9 law In this state. In addition, whenever a vacancy or judgeship exists In a 

10 particular supreme court district, the chief justice of the. supreme court and 

11 three additional members shall be selected from persons domiciled in the 

12 particular supreme court district by the judicial nominating commission 

13 selection board to serve on the supreme court nominating commission; 

14 however, If the vacancy or judgeship to be filled is that of the chief justice, 

15 the next Judge oldest in point of service on the supreme court shall serve on 

16 the nominating commission. The selection of the three additional members 

17 by the judicial nominating commission selection board shall be done in such a 

. 18 manner that one member shall be a person who is licensed to practice law in 

19 this state and two members shall be persons who are not licensed to practice 

20 law in this state. 

21 (I)) Court of Appeal Nominating Coramission. Each court of appeal 

22 circuit shall have a. nominating commission composed of nine members 

23 selected by the judicial nominating commission selection board as follows: 

24 the chief judge of the circuit or if the vacancy or judgeship to be filled is 

25 that of the chief judge, the next judge oldest in point of service on the court 

26 of appeal of the circuit; two persons who are domiciled in each court of 

27 appeal district in the circuit; and two persons who are domiciled in the court 

28 of appeal district in which the vacancy or judgeship exists; however, if the 

29 vacancy or judgeship Is to be filled from the circuit at large, one additional 

30 person who is domiciled in each court of appeal district of the circuit other 

31 than the district represented by the chief judge or next judge oldestein point 

32 of service serving on the commission. The selection of the nine-member 

33 nominating commission by the judicial nominating oommission selection board 

34 shall be done In such a manner that in addition to the chief judge, three 

35 members of the commission shall be persons who are licensed to practice law 

Page 4 

CODING: Words In etreek-through type are deletions from existing law; 
words tkn_t_1Encored Kgand boldf are additions. 



Elpv4, ,-- •EIE 20:4414. SCPV4T( 5G4-34:-Ee9s- . • F.4 n 

1 

2 

3 

4 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

19 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

BR8 88-341 

in this state and five members of the commission shall be persons who are not 

licensed to practice law in this state. 

It) District Court Nominating Commlwon. Each judicial district of 

the state shall have a nominating earn mission composed of nine members 

selected as follows: five members shall be selected by the chairman of the 

court of appeal nominating commission from the circuit in which the judicial 

district Is located from the membership of such commission; selection of 

these five members shall be done In such manner that two members shall be 

parsons licensed to practice law In this state and three members shall be 

persons not licensed to practice law In this state. In addition, the chief judge 

of the district court and three members shall be selected by the judicial 

nominating commission selection board from persons domiciled in the judicial 

district in which the particular vacancy or judgeship is located; the selection _ 

of these three members shall be done in such a manner that one member shall 

be persons licensed to practice law In this state and two members shall be 

persons not licensed to practice law in this state. If the vacancy or judgeship 

to be filled is that of the chief judge, the next judge oldest in point of service 

on the district court shall serve on the nominating commission. 

CIXa) The legislature shall provide by law for submission of nominees to 

the jedleial nominating commission selection board to serve on each 

nominating commission which shall include the following: names of persons 

licensed to practice law In this state shall be submitted to the judicial 

nominating commission selection board from each professional association of 

attorneys residing in the judicial district and names of persons not licensed to 

practice law In this state shall be submitted by other established civic or 

profesdonal organizations active in the judicial district. 

Os) Members of each nominating commission shall serve overlapping 

terms of six years, following initial terms fixed by law. No member shall 

serve more than two 'consecutive terms on a commission. Each commission 

shall elect a chairman. The term of each chairman shall be for one year and 

no member shall serve for more than two consecutive terms as chairman. 

ie) Commission members shall serve on the commission without pay but 

shall be allowed reimbursement for actual expenses incurred in performance 

of their official duties. 

fe) When a vacancy occurs in the membership of a nominating 

Page $ 

CODING: Words in *twit-through type are deletions from existing law; 



• P%41 IBE 10:50 LA. SCf4citE 504-34i-86,96, 

• • P.9 .13 

*MU 88-311 

1 commission, the vacancy shall be filled for the unexpired portion of the term 

2 In the same manner as the previous selection. 

3 (e) No member of a nominating commission shall serve in a judicial 

4 office its the district in which the nominating commission is located for a 

period of three years after expiration of his term on the nominating 

6 commission. 

7 (f) No person serving on a nominating commission shall, nor for two 

8 years prior to such service, bold an elective office, an appointive office, or 

9 be an employee in the government of this state or in the government of a 

10 political subdivision of this state or in the government of the United States 

11 nor shall he be a member of any national, state, or local political committee 

12 of a political party or faction; provided that this Subparagraph shall not 

13 preclude or prohibit any judge sitting on a nominating commission from 

14 seeking appointment to a higher or lower judicial office. 

15 (g) All votes by members of a nominating commission shall be 

16 confidential alxi shall be recorded in the minutes of the commission meeting 

17 and shall be reviewed by the supreme court. The name and record of each 

18 nominee submitted to the governor by a nominating commission shall be 

19 considered public record. The name and record of any person considered by a 

21 commission sha/1 not be a public record but shall remain confidential and 

22 maintained by the supreme court for possible reconsideration should a 

23 subsequent vacancy or judgeship arise. 

24 (4) The five standing members of the supreme court nominating 

25 commission shall establish necessary guidelines and rules and regulations 

26 which shall be followed by each nominating commission created under the 

27 provisions of Paragraph (1). 

20 . nominating commission but who • is not submitted to the governor by the 

28 (5) The State Civil Service Commission shall provide staff support for 

29 each nominating commission and shall perform such powers, duties, and 

30 functions as provided by law to assist each nominating Commission in 

31 performance of its official duties. 

32 Article V, Section 22(0) is all pros ed new law. 

33 (G) Transition. Each Justice of the supreme court, judge of a court of 

34 appeal, or Judge of a district, family, or juvenile court serving on January 1, 

35 1989 shall serve through December 91, 1995. Thereafter, upon expiration of 

Page 

CODING: Words in struek-tbroark type are deletions from existing law; 
words anderscored and boldfaced are additions. 



^ Lt. it 

• SRS 88-341 

. 3 

1 his term, he shall be subject to the system of merit retention provided in this 

2 Seetion. 

3 Section 2. Be it further resolved that this proposed amendment shall be 

4 submitted to the electors of the state of Louisiana at the presidential election to 

5 be held in November, 1988. 

6 Section 3. Be it further resolved that on the official ballot to be used at the 

7 election there shall be printed a proposition, upon which the electors of this state 

8 shall be permitted to vote FOR or AGAINST, to amend the Constitution of 

9 Louisiana, which proposition shall read as follows: 

10 To provide a system of merit selection and retention of judges of the 

11 supreme court, court of appeal, and district, family, and juvenile 

12 courts to provide a system of merit selection and retention of such 

13 judges; to create a judicial nominating oommlssion selection board and 

14 'official nominating commissions and provide for their powers, duties, 

15 and functions under a merit selection system; and to provide a 

16 transition for incumbent judges. (Adds Article V, Section 12(D), (E), 

17 (11), and (G)) 

18 

19 

The original instrument and the following digest, which 
20 eaastitutes no part of the legislative instrument, were 
1 prepared by Thomas L. Tyler. 
2 

22 

DIGEST 
23 

Proposed constitutional amendment requires that, beginning on January 1, 1989, 
24 every newly-ereated judgeship or vacancy in the office of justice of the supreme 

court, judge of a court of appeal, or judge of a district, family, or juvenile court 
25 from a judicial district be filled under a system of merit selection of judges. 

Creates.a judicial nominating commission for each such district, circuit, or judicial 
26 district and requires that the commission nominate two or three persons for each 

office of judge for submission to the governor. Requires that the governor select 
27 one of the nominees to serve hi the respective office of judge. Requires Senate 

consent on selection. Requires that a majority of the supreme coto1 select the 
28 judge if the governor fails to select one of the nominees within 60 days after 

submission by the commission. Provides an initial term of at least two years for 
29 such judge and if retained at a retention election held at the regular congressional 

primary election, he serves a full term as provided in the constitution. Requires 
30 that every jute selected thereafter for the office of a judge under the system of 

merit selectiam shall be subject to a system of merit retention. Prohibits a judge 
31 who loses a retention election from being nominated for the subsequent 
32 consecutive term of office of judge. 

Proposed constitutional amendment creates a system of merit retention, beginning 
33 on January 1,1989, for such judges. Provides that not less than 90 days prior to the 

next regular eengressional primary election preceding expiration of his term, such 
34 judge may file with the secretary of state a declaration of candidacy to succeed 

himself In the office of judge. U the declaration is not filed a vacancy results upon 
35 evpirstion of lie term which vacancy is filled under the system of merit selection. 

Requires the secretary of state, upon filing of the declaration, to cause to be 

Page 7 

CODING: Words in streek-eloreegli type are deletions from existing law; 
words ynderseared and boldfaced are additions. 



PV4 a 'I3E 10:51 LA. SEPV4TE SO4-342-9399 F.10 11 

US 81-341 

1 included on the ballot for submission to the voters in the supreme court district, 
°ourt of appeal circuit, or judicial district at the next regular congressional 

2 primary election the question of retention of the particular judge In the same 
judgeship. Requires that if a majority vote to retale the judge, he is deemed to 

3 have been sleeted for another term; if a majority vote against retention, then upon 
expiration of his term a vacancy shall exist in the office of judge which shall be 

4 filled ender the system of merit selection. 

5 Proposed eoristitutional amendment creates a judicial nominating commission 
selection board and nominating corn missions. Requires that the judicial nominating 

6 COM albSiOn selection board and each nominating commission reflect substantially 
the racial and minority characteristics of the population of the respective supreme 
court district, court of appeal circuit, and judicial district without compromising 
the over-riding goal of achieving consistent excellence in the judiciary. Requires 

8 that the judicial nominating commission selection board be composed of three 
members from each court of appeal emit selected by a majority vote of the 

9 members of the legislative delegation representing each court of appeal circuit. 
Requires that the legislature provide by law for submission of nominees on the 

10 selection board from professional and civic groups or organizations. 

11 Promised constitutional amendment creates the following nominating commissions: 

12 (a) 71t• supreme court nominating commission composed of five standing 
members *elected as follows: the chairman of each court of appeal 

13 nominating commission shall select a member from his respective commission 
to serve on the supreme court nominating commission; this selection shall be 

14 done in such a manner that two persons are licensed to practice law in this 
state and three are not licensed to practice law in this state. In addition, 

15 whenever a vacancy or judgeship exists in a particular district, the chief 
justice of the supreme court and three additional members shall be selected 

16 by the judicial nominating commission selection board in such a manner that 
ane person be licensed to practice law in this state and two not be licensed to 

17 practice law in this state. 

18 Provides that if the vacancy or judgeship to be filled is that of the chief 
*nice then the next judge oldest in point of service on the supreme court 

19 dull serve on the nominating commission. 

20 (b) The court of appeal nominating commission composed of nine members 
selected by the selection board as follows: the chief judge of the circuit or if 

21 the vacancy or judgeship to be fileki is that of the ehief judge, the next judge 
ddest in point of service on the court of appeal of the circuit; two persons 

22 who are domiciled in each court of appeal district in tho circuit; and two 
persons who are domiciled in the court of appeal district in which the 

23 vacancy or judgeship exists; however, if the vacancy or judgeship is to be 
filled from the circuit at large, one additional person who is domiciled in 

24 esch court of appeal district of the circuit other than the district represented 
by the chief judge or next judge oldest in point of service serving on the 

25 eornmISsion. Selection of these members shall be done in such a manner that 
four members be persons licensed to practice law in this state and five 

26 members not be licensed to practice law in this state. 

27 (c) ?be district court nominating commission composed of nine members 
selected as follows: five members dual be selected by the chairman of the 

29 eourt of appeal nominating commission from the circuit in which the judicial 
district is located from the commission membership; selection of these five 

29 members shall be done in such a manner that two members be licensed to 
practice law in this state and three members not be licensed to practice law 

30 Is this state. In addition, the chief judge of the district court and three 
'members shall be selected by the selection board from persons domiciled in 

31 the judicial district in which the vacancy or judgeship exists in such a manner 
that one member be licensed to practice law in this state and two members 

32 nos be licensed to practice law in this state. 

33 Provides that If the vacancy or judgeship to be filled Is that of the chief 
judge of the district court, the next oldest judge in point of service on the 

34 &strict court shall serve on the nominating commission. 

35 Requires the legislature to provide by law for submission of nominees to the 
selective board to serve on the nominating commission and that such include the 

Page II 

CODING Words in struele-threugh type are deletions from existing law; 
words eseie.rscored and boldfaced are additions. 



eiV4 , 2* 1X 10:4! LA. SENATE 504 - 34: -8e95. C .6 I I 

4110 
SRS 18-341 

• 
1 

2 

3 

following: names of persons licensed to prsctice law in the state shall be 
submitted by each proteuional association of attorneys residing in the district and 
names of persons not licensed to practice law shall be submitted by other 
established civil or professional organisations active in the district. 

Proposed constitutional amendment provides the following relative to the 4 
nominating corn Mission: 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

IS 

16 

17 

18 

19 

(f) 

(a) Members serve six-year overlapping terms; no member can serve more than 
two consecutive terms on a commission; and each commission elects a 
chairman who serves a one-year term as chairman and who shall serve no 
more than two consecutive terms as chairman. 

(b) Members shall serve on the commission without pay but shall be reimbursed 
for actual expenses Incurred. 

(e) Vacancies on the commission shall be filled for the unexpired term in the 
same manner as the previous selection. 

(d) No member shall serve in a judicial office in the district for a period of three 
years after expiration of his term on the commission. 

(e) No member shall, nor for two years prior to such service on the commission, 
hold an elective office, appointive office, or be an employee in the 
government of the state, the government of the United States, or a political 
subdivision of such, nor shall be be a member of any national, state, or local 
political committee of a political party or faction. Provides that this shall 
not preclude or prohibit a judge on a nominating commission from seeking 
appointment to a higher or lower judicial office. 

All votes of the commission are confidential and shall be recorded in the 
minutes and shall be reviewed by the supreme court; the name and record of 
each nominee submitted to the governor is a public record; the name and 
record of any person considered but not submitted to the governor is not 
public and shall remain confidential and maintained by the supreme court for 
possible reconsideration for subsequent vacancies or judgeships. 

(g) The State Civil Service Commission shall provide staff support to the 20 
nominating commission and perform such powers, duties, and functions as 

21 provided by law. 

22 Proposed constitutional amendment requires that each justice of the supreme 
court, judge of a court of appeal, or judge of a district, family, or juvenile court 

23 serving on January 1, 1989 shall serve through December 31, 1995. Thereafter, 
upon expiration of his term, he shall be subject to the system of merit retention. 

24 
Specifies submission of the amendment to the voters at the presidential election in 

25 November, 1983. 

26 (Adds Const. Art. V, Sec. 22(D), (E), (F), and (G)) 

27 

28 

29 

30 

31 

32 

33 

34 

35 

pummary of Amendments Adopted by Senate 

Committee Amendments Proposed by Senate Committee on Judiciary S to 
the Oriffrial bill.  

Adds provision that the appointment of a judge by the governor be made 
with the consent of the Senate. 

2. Requires each judge seeking to succeed himself to file a declaration of 
candidacy with the secretary of state and provides for the effects of 
such a declaration. 

1. 

3. Creates the judicial nominating commission selection board and 
provides for its composition and functions. 

Page 9 

CODING: Words in struck-through type are deletions from existing law; 
worth lindersewed and boldfaced are additions. 



PV4 , ?i • 30:5.? sEt*:.TE so4-34z-oes.s. 

• 
8RS $1-341 

• 
F.1112 

• 

2 

3 

4 

5 

6 

7 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

to 

21 

22 

23 

24 

25 

26 

27 

28 

29 

30 

31 

32 

33 

34 

35 

4. Deletes the State Civil Service Commission as the entity naming 
persons to the various nominating commissions. 

S. Requires that the chief justice or chief judge of the respective 
jurisdiction serve on the respective nominating commission. 

6. Deletes prohibition against supporting, endorsing, or opposing candidates for public office by certain groups which will submit 

potential nominees to the selection board for service on a nominating 
commission. 

7. Deletes prohibition against a member of a nominating commission from 
serving in a judicial office. 

8. Reduces !mg 4 to 3 years the period which must expire before a person 
on a nominating commission can be nominated for judgeship. 

9. Provides that a judge serving on a nominating commission is not 
precluded or prohibited from seeking a higher or lower judicial office. 

10. Provides that any judge serving on Jan. 1, 1989 shall serve through Dec. 
31, 1995 and thereafter, be subject to merit retention. 

Page 10 

CODING: Words in efruele-41weergh type are deletions from existing law; 
words underscored and boldfaced are additions. 



• 

STATE OF LOUISIANA: 

PARISH OF CADDO : 

BEFORE ME, the undersigned authority, came and appeared 

ROBERT G. PUGH, attorney for CHARLES E. "BUDDY" ROEMER, in his 

capacity as Governor of the State of Louisiana; FOX McKEITHEN, in 

his capacity as Secretary of State •of Louisiana; and JERRY M. 

FOWLER, in his capacity as Commissioner of Elections of the State 

of Louisiana, defendants in the foregoing suit, who after being 

duly sworn did state that statements contained in the foregoing 

Defendants' Answers to United States' First Set of Requests for 

Admission and Defendants' Answers to United States' First Set of 

Interrogatories are true and correct to the best of the affiant's 

knowledge and belief. 

Robert G. Pugh 

SWORN TO AND SUBSCRIBED before me this 25th day of 

October, 1988. 

• A444.4.,......) 
Notary Public in and for Caddo Parish, Louisiana. 

My Commission Expires at Death. 



• 

CERTIFICATE  

I HEREBY CERTIFY that a copy of the above and foregoing 

Defendants' Answers to United States' First Set of Requests for 

Admission and Defendants' Answers to United States' First Set of 

Interrogatories, has this day been served upon the United States 

of America, through its counsel of record, Robert S. Berman, 

Esquire, Attorney, Voting Section, Civil Rights Division, 

Department of Justice, P. 0. Box 66128, Washington, D.C. 

20035-6128 by depositing the same in the United States Express 

Mail, postage prepaid, properly addressed, and upon the 

following: 

William P. Quigley, Esquire 
901 Convention Center Blvd. 
Fulton Place, Suite 119 
New Orleans, Louisiana 70130 

Julius L. Chambers, Esquire 
Charles Stephen Ralston, Esquire 
C. Lani Guinier, Esquire 
99 Hudson Street 
16th Floor 
New York, New York 10013 

Ms. Pamela S. Karlan 
University of Virginia Law School 
Charlottesville, Virginia 22904 

Ron Wilson, Esquire 
Richards Building, Suite 310 
837 Gravier Street 
New Orleans, Louisiana 70112 



Roy Rodney, Esquire 
643 Magazine Street 
New Orleans, Louisiana 70130 

by depositing the same in the United States Mail, postage 

prepaid, properly addressed. 

Shreveport, Caddo Parish, Louisiana, this the 25th day 

of October, 1988. 

Robe/G. iugh, 
Of Counsel