Draft Affidavit of Bernard Grofman

Working File
July 10, 1984

Draft Affidavit of Bernard Grofman preview

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  • Case Files, Thornburg v. Gingles Hardbacks, Briefs, and Trial Transcript. Draft Affidavit of Bernard Grofman, 1984. 245d8c84-d592-ee11-be37-00224827e97b. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/bc695b67-6064-46ca-9919-b3b248425237/draft-affidavit-of-bernard-grofman. Accessed July 06, 2025.

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I, Bernard Grofman, hereby declare that the following ls true. In

order to ascertaln the potentlal effects on the representatlon of

mlnorlty strength of the mlxed slngle and multlmember dlstrict plan

proposed for the Ullson county area I examlned the percentage of black

populatlon ln the slngle member dlstrlct and the proposed three-member

multtmember dlstrlct as compared to the black percentages whlch could be

drawn ln four stngle-member dlstrtcts whlch do not fragrnent black

populatlon concentratlons. (These dlstrlcts had black populatlons of

66t, 48.3t,23.31 and 20.2%, compared to 69.1t black tn the proposed

slngle-member dlstrlct and 29.6% black ln the proposed three member

multt-member dlstrict.

(2) My conclustons are that

(a) because of the magnltude of raclal polarizatlon ln ttllson county,

tt ls my professlonal Judgment that black candldates do not have any

slgnlficant llkelihood of belng elected ln the proposed three-member

multt-member dlstrlct .

(b) Absent dramatlc changes ln the magnltude of raclal polarlzation

ln lltlson County, black candldates wlII be unllke1y to be elected from

the proposed three member multl-member dlstrtct at any tlme during the

next decade, slnce that dlstrlct ts only 29.6t black. In contrast; Black

vottng strength ls such that, lf there were a stzeable lncrease tn whlte

crossover votlng for black candidates, there exlsts a real posslbllity

that a black candldate mlght be elected from the slngle-member dlstrict

whlch ls 48.3? black.

(c) Clven the degree of raclal polarlzatton ln wllson county, voters

are unlikely to have a slgnlflcant tnfluence on electlons Eor any of the



three candldates tn the proposed three member multl-member dlstrtct. In

contract, black voters can be expected to have a slgnlflcant ln-fluence tn

electlons ln the 48.3t black slngle-member distrtct whlch m19ht be drawn.

(<t) By creatlng one slngle-member dtstrlct and one multt-member

dtstrtct, the proposed plan makes lt ltkely that representattves from the

multl-member dtstrlct (etected by a primarlly whtte electorate) will be

seen as the representatives of the area, whlle the representattve from

the slng1e-member dtstrlct (the only dlstrtct ln whtch black voters will
habe a slgnlftcant lnfluence) wlll be seen as representating a narrowly

deflned constltuency. Horeover, the representatlves from the

multt-member dlstrlct, chosen by the same set of voters, wlII be llkely
to vote as a bloc.

6*r-*/
July I0, 1984 

I
Professor of PoIittcal Sclence
Unlverstty of Caltfornia, Irvlne
Irvtne, Callfornla 927L7

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