Draft Affidavit of Bernard Grofman
Working File
July 10, 1984
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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 December 03, 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