Memorandum from Suitts to North Carolina Reapportionment Group
Correspondence
October 13, 1981
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Case Files, Thornburg v. Gingles Hardbacks, Briefs, and Trial Transcript. Memorandum from Suitts to North Carolina Reapportionment Group, 1981. 597bc85d-d892-ee11-be37-6045bddb811f. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/bc91c8f9-07fb-4f6f-bf3c-5a8777dc3944/memorandum-from-suitts-to-north-carolina-reapportionment-group. Accessed December 05, 2025.
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rONY HAFFISON, PTari.oI
UAFY FRANCES DEnFNEB, VElPrxir.nt .
a JUL|US L. OtAMBEFS, Prrr Pr..t .lrt
SIEVE SUFIS. Erocuth. Oirctor a JG€PH HAIS. Cq,lI l
75 TARIETTA STREET. N.W. ATLANTA, GEORGIA 30303 (.04) 522-t76a
MEMORANDI,]M
TO: The North Carolina Reapportionment Group
FROM: Steve Suitts
RE: Rough Draft of Subnission to Justice
DATE: October 13, 1981
I have placed under this cover a rough draft of the document
requesting the Department of Justice to object to the North Carolina
Reapportionment plans concerning the house and senate of the
General Assenbly and the Congressional districts. You will note,
however, that the section concerning the Congressional reapportion-
ment is absent as is most of the appendices to which reference is
nade in the draft. There should also be a final section arguing
that the state has failed to carry the burden of proof in the
adninistrative proceeding in its submission to the Department of
Justice.
ment of Justice to delay the reapportionment plans which the
Departnent has before it. Nevertheless, I think that we should
proceed in opposing the present proposals.
Of course, there will apparently be no delay in the Justice
Departmentts consideration of the L967 anendments to the State
Constitution requiring that lines be drawn respecting county boun-
daries. For that reason, I gather we should begin to redirect our
attention towards that submission more than towards the reapportion-
ment plans thenselves.
I hope to get sone confirmation from the Department of Justice
within the next day or so about what it intends to do with the
present reapportionment plans. If they intend to proceed, we should
shore up this draft and have it filed on someone I s behalf in the
next few days.
I hope to see you all soon.
SS/tc