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 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