Metropolitan County Board of Education v. Kelley Brief in Opposition

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January 1, 1982

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Date is approximate. Metropolitan County Board of Education of Nashville and Davidson County, TN v. Kelley Brief in Opposition

Collection
- Brief Collection
Taxonomy
Identifier
- c108a509-bf9a-ee11-be36-6045bdeb8873

Cite this item

Brief Collection, LDF Court Filings. Thornburg v. Gingles Joint Appendix Exhibits Vol. 1, 1984. 5afe1323-c69a-ee11-be37-00224827e97b. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/e1fd6f3a-4347-49da-94c6-65a5843624b0/thornburg-v-gingles-joint-appendix-exhibits-vol-1. Accessed July 01, 2025.

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No. 83-1968

IN THE

(Etfurt at % Irnteii States
O c t o b e r T e r m , 1985

L a c y H. T h o r n b u r g , et al.,
Appellants,

R a l p h G i n g l e s , et al.,
Appellees.

On Appeal from the United States District Court
for the Eastern District of North Carolina

JOINT APPENDIX EXHIBITS

VOLUME I

J erris L eonard
K a t h l e e n H e e n a n M c G u a n
L eonard & M c G u a n , P.C.
900 17th Street, N.W.
Suite 1020
Washington, D.C. 20006
(202) 872-1095

Counsel for Appellants

Charlotte, North Carolina 28202
(704) 375-8461

Counsel for Appellees, Ralph Gingles, et al.

JURISDICTIONAL STATEMENT FILED JUNE 2 , 1984

PROBABLE JURISDICTION NOTED APRIL 29 , 1985

J u l iu s C h a m b e r s
E r ic S c h n a p p e r
C . L a n i G u in ie r
N A A C P L eg al D e f e n se a n d

E d u c a t io n a l F u n d I n c .
16th Floor, 99 Hudson Street
New York, New York 10013
(212) 219-1900

L e slie J . W in n e r
F e r g u so n , W a t t , W a l l a s ,

& A d k in s , P .A .
951 S. Independence Blvd.

Ex-1

PUGH/EAGLIN PLAINTIFFS’ EXHIBIT NO. 4

Table 1-A
Comparison of Black Population and Black

Representation in the North Carolina Legislature
1940-1982

Year
# of

Blacks

Population
Total Popu

lation
7c

Black

NC Senate
# o f 7t

Blacks Black

NC House
# o f %

Blacks Black

1940 981,298 3,571,623 28 0 0 0 0
1942 0 0 0 0
1944 0 0 0 0
1946 0 0 0 0
1948 0 0 0 0

1950 1,078.808 4,061,929 27 0 0 0 0
1952 0 0 0 0
1954 0 0 0 0
1956 0 0 0 0
1958 0 0 0 0

1960 1,156,870 4,556,155 25 0 0 0 0
1962 0 0 0 0
1964 0 0 0 0
1966 0 0 0 0
1968 0 0 1 .8

1970 1,126,478 5,082,059 23 0 0 2 1.6
1972 0 0 \>*_> 2.5
1974 2 4 4 o

1976 2 4 4 ■).
1978 1 2 3 2.5

1980 1,316,050 5,874,429 22 1 2 3 2.5
1982 1 2 11® 9.1

Sources: Thad Eure. X o rth C a ro lin a L e y i s la t ire D ire c to r 19S1-19S2. 198C4-19S4
Thad Eure. X o r t l i C a ro lin a M a n u a l. Raleigh: Publications Division. 1941-1979
LJ.S. Bureau of Census, 1940, 1950, 1900. 1970. 19X0

::Six of these were elected from majority black districts that the General Assembly was forced to draw by the
Federal Courts.

PLAINTIFF S EXHIBIT
11 App 3 Gingles

Appendix 3: “Effects of Multimember House and State Senate Districts
in Eight North Carolina Counties, 1978-1982”

CONDENSED SUMMARY TABLE 1

KEY (X,Y,Z,Q)
X = number of black

candidates
Y = total number of candidates

(including blacks)
Z = number of winning-

candidates
Q = number of winning black

candidates
Level of White Voter Support for Black Candidates vs. Black Voter Support for Black Candidates in Eight North Carolina Counties, House and Senate

Primary and General Elections in which there was at least one Black Candidate, 1978-1982.*

Proportion of Proportion of Proportion of Proportion of
white voters black voters white voters black voters
for black for black for black for black

GENERAL candidate(s) candidate(s) PRIMARY candidate(s) candidate(s)

(5) Mecklenburg & Cabarrus

(1, <>, 4, 1) 1978 Senate .41 .94 (i, 5. 4, 1) 1978 Senate .47 .87
(i, 5, 4, 0) 1980 Senate .2:1 .78

(1,7, 4, 0) 1982 Semite .94 (i. (i, 4, 1) 1982 Senate .32 .83

(9) Mccklenbui g
(1, (>, 4, 1) 1978 Senate .40 .94 (i, 5, 4, 1) 1978 Senate .50 .87

(i, 5, 4, 0) 1980 Senate .25 .79
(1, 1(5, 8, 0) 1980 House .28 .92 (i. lit. 8, l) 1980 House .22 .71
(1, 7, 4, 1) 1982 Senate .31 .94 (i, (!, 4, 1) 1982 Senate .33 .83
(2, 18, 8, 1) 1982 House .42 .29 .92 .88 (2, 9, 8, 2) 1982 House .50 .30 .79 .71

(5) Cabarrus
(1, (5, 4, 1) 1978 Senate .38 .92 (I, 5, 4, (1) 1978 Senate .35 .75

(1, 5, 4, 0) 1980 Senate .21 .79
(1, 7, 4, 0) 1982 Senate .37 .94 (1, li, 4, 0) 1982 Senate .80 .70

Polk wins in
1982 Meek. Sen.
goner.
Alexander loses
in 1978 Cabarrus
primary.
Polk loses in
1982 Cabarrus
primary.

Ex-2

TABLE 1 (continued)

Proportion of Proportion of
white voters black voters
for black for black

GENERAL candidate(s) candidate(s)

((>) Durham
(1, 4, 2, (l) 1978 Senate .17 .05

(Rep. B)
(1, 3, 3, 1) 1978 House .48 .79
(1, 3, 3, 1) 1980 House .49 .90
(1, 4, 3. 1) 1982 House .48 .89

(7) Forsyth
(2, 9, 5, 0) 1978 House .82 .88 .95 .25

(1 Rep B) .82 .90
(1, 10, 5, 0) 1980 House .42 .40 .87 .94
(2, 8, 5, 2)
(5) Wake

1982 House

(1, f>, 13, 1) 1980 House .44 .90
(1, 17, <>, 1) 1982 House .45 .91

(3) E-W-N

(5)
Edgecombe

1982 County
(2, 4, 2) Commissioner .88 .80 .91 .94

Proportion of Proportion of
white voters black voters
for black for black

PRIMARY candidate(s) candidate(s)

.89 .92

(2, 7, 8, 1) 1978 House .10 .10
X

.82 .90
No Primary 1980 House X
(2, 4, 8, 1)' 1982 House .20 .87

(8, 10, 5, 1) 1978 House .28 .08 .17 .70 .29 .58
(1, 8, 2, 0) 1980 Senate .12 .01
(2, 7, 5, 1) 1980 House .40 .18 .80 .30
(2, 11, 5, 2) 1982 House .25 .80 .80 .91

(1, 12, 0, 0) 1978 House .21 .70
(1, 9, 0, 1) 1980 House .81 .81
(1, 15, 0, 1) 1982 House .89 .82

1982 House (1, 7, 4, 0) .04 .00
1982 1st Cong

Primary (1, 8, 2, 1) .02 .84
1982 2nd Cong-

Primary (1, 2, 1, 0) .05 .91

1982 House (1, 7, 4, 0) .02 .08
1982 1st Cong-

Primary (1, 8, 2, 1) .02 .84
1982 2nd Cong

Primary (1, 2, 1, 0) .08 .97
1982 County 0 0 .04 .02

Commissioner (4, 10, 8, 2) .14 .27 .75 .82

Michaux wins in

Edgecombe

Ex-3

TABLE 1 (continued)

GENERAL

(4) Wilson

(5) Nash

Proportion of Proportion of Proportion of Proportion of
white voters black voters white voters black voters
for black for black for black for black
candidate(s) candidate(s) PRIMARY candidate(s) candidate(s)

1982 House (1, 7, 4, 0) .02 .70
1982 1st Cong- .00 .9(5

Primary (1, 3, 2, 0) .07 .98
1982 2nd Cong .82 .77

Primary (1, 2 , 1, 0)
1970 County

Commissioner (1, 1 , 7,0)

1970 House
1982 1st Cong-

(1, 7, 4, 0) .02 .58

Primary (1, 3, 2, 1) .00 .73
1982 2nd Cong-

Primary (1, 2, 1, 0) .00 .81
1982 County

Commissioner (1, <>, 3, 0) .09 .82

:4n Edgecombe, Wilson and Nash there was only black candidate for House or Senate in the period 197X-19H2. Data for those counties are based in addition on a 1970 County Commission race in
Wilson, 1982 Congressional Primaries, and Edgecombe and Nash 19X2 County Commission Primaries and Ceneral Elections.

N - 58
Actual district races - MO House & Senate (P&G)

1 County Commissioner (P&(1)
2 Cong Primaries

M<>

Ex-4

Ranking of White Voter Support for Black Candidates vs. Black Voter Support for Black Candidates in Eight North Carolina Counties,
House and Senate Primary and General Elections in which there was at least one Black Candidate, 1978-1982.*

CONDENSED SUMMARY TABLE 2

Ranking of white Ranking of black Ranking of white Ranking of black
voters for black voters for black voters for black voters for black

GENERAL candidate(s) candidate(s) PRIMARY candidate(s) candidate(s)

(5) Mecklenburg & Cabarrus
(1, <), 4. 1) 1978 Senate 4 1 (i, 5, 4, 1) 1978 Senate last 1

a, 5, 4, 0) 1980 Senate last 1
(1, 7, 4, 0) 1982 Senate (i 1 (i, <», 4, 1) 1982 Senate 5 1

(9) Mecklenburg
(1, (i, 4, 1) 1978 Senate 4 1 (i, 5, 4, 1) 1978 Senate last 1

(i, 5, 4, 0) 1980 Senate last 1
U, Hi, 8, 0) 1980 House last 1 (i. 13, 8, 1) 1980 House 10 1
(1, 7, 4, 0) 1982 Senate 0 1 (i, 0, 4, 1) 1982 Senate 5 1
(2, 18, 8, 1) 1982 House 7 14 1 2 (2, 9, 8, 2) 1982 House 7 last 1 2

(5) Cabarrus
(1, (i, 4, 1) 1978 Senate 5 1 (1, 5, 4, 0) 1978 Senate last 1

(1, 5, 4, 0) 1980 Senate last 1
(1, 7, 4, 0) 1982 Senate 0 1 (1, (i, 4, (1) 1982 Senate 5 1

((>) Durham
(1,4, 2, (!) 1978 Senate last 2,

(Rep B)
(1, 3, 3, 1) 1978 House last 1 (2, 7, 3, 1) 1978 House last <) 2 1
(1. 3, 3, 1) 1980 House last 1 N( Primary 1980 House X X
(1, 4, 3, 1) 1982 House 1 (2, 4, 3, 1) 1982 House next to last last 2 1

(7) Forsyth
(2, !), 5, 0) 1978 House last next to last 1 (j (3, 10, 5, 1) 1978 House 7 last 8 a 2 l

(1 Rep B) (1, 3, 2, 0) 1980 Senate last i
(1, 10, 5, 0) 1980 House last 1 (2, 7, 5, 1) 1980 House next to last last 1 2
(2. 8, 5, 2) 1982 House last next to last 2 1 (2, 11, 5, 2) 1982 House 8 4 1 2

Alexander loses
in 1078 Cabarrus

primary.
Polk loses in
1982 Cabarrus
primary.

Ex-5

(6) Wake
(1, 13, 6, 1)
(1, 17, (i, 1)

(3) E-W-N

(5) Edgecombe

(3, 4, 3, 2)

(4) Wilson

TABLE 2 (continued)

GENERAL

1982 County
Commissioner

Ranking of white Ranking of black Ranking of white
voters for black voters for black voters for black
candidate(s) candidate(s) PRIMARY candidate(s)

0 1 (1, 12, (), 0) 1978 House 9
3 1 (1, 9, 0, 1) 1980 House 8

(1, 15, 6, 1) 1982 House 5

1982 House
1982 1st Cong-

(1, 7, 4, 0) last

Primary
1982 2nd Cong-

(1, 3, 2, 1) last

Primary (1, 2, 1, 0) last

1982 House
1982 1st Cong-

(1, 7, 4, 0) last

Primary
1982 2nd Cong-

(1, 3, 2, 1) last

Primary (1, 2, 1, 1) last
2 3 2 1 1982 County (4, 10, 3, 2) last tied for last

Commissioner

1982 House
1982 1st Cong-

(1, 7, 4, 0) last

Primary
1982 2nd Cong-

(1, 3, 2, 0) last

Primary
1970 County

(1, 2, 1, 0) last

Commissioner (1, 13, 7, 0) 11

Ranking of black
voters for black
candidate(s)

1
1
1

1
4 3 2 1

Miehaux wins in
Edgecombe only

Ex-6

(4) Nash

TABLE 2 (continued)
Ranking of white Ranking of black Ranking of white Ranking of black
voters for black voters for black voters for black voters for black
candidate(s) candidate(s) PRIMARY candidate(s) candidate(s)

1976 House (1, 7, 4, 0) 7 1
1982 1st Cong

Primary (1, 3, 2, 1) tied for last 1
1932 2nd Cong

Primary (1, 2, 1, 0) last 1
1982 County

Commissioner U, 6, 3, 0) 6 1

*ln Edgecombe, Wilson and Nash there was only black candidate for House or Senate in the period 11)78-1982. Data for those counties are based in addition on a 197(5 County Commission race in
Wilson, 1982 Congressional Primaries, and Edgecombe and Nash 1982 County Commission Primaries and General Elections.

N = 53
Actual district races - 30 House & Senate (P&G)

•1 County Commissioner (P&G)
_2 Cong Primaries
:«}

Ex-7

Level of White Voter Support for Black Candidates vs. Black Voter Support for Black Candidates in Eight North Carolina Counties,
House and Senate Primary and General Elections in which there was at least one Black Candidate, 1978-1982.*

CONDENSED SUMMARY TABLE 3

Proportion of Proportion of Proportion of Proportion of
the votes cast the votes cast the votes cast the votes cast
by white by black by white by black
voters which voters which voters which voters which
go to the black go to the black go to the black go to the black
candidate(s) candidate(s) candidate(s) candidate(s)

GENERAL PRIMARY

P’wn P'nii f^WB P'm; P'm,

(5) Mecklonbui g & Cabarrus
(1, 6, 4, 1) 1978 Senate .16 .38 (1, 5, 4, 1) 1978 Senate .10 .53

(1, 5, 4, 0) 1980 Senate .09 .52
(1, 7, 4, 0) 1982 Senate .11 .40 (1, 6, 4, 1) 1982 Senate .12 .49

(9) Mecklenburg
a , <i, 4, i) 1978 Senate .15 .38 (1, 5, 4, 1) 1978 Senate .17 .55 Alexander

(1. 5, 4, 0) 1980 Senate .09 .53 loses in 1978
(1, 1(>, 8, 0) 1980 House .05 .23 (1, 13, 8, 1) 1980 House .04 .34 Cabarrus
a , 7,4, i) 1982 Senate .11 .47 (1, 6, 4, 1) 1982 Senate .11 .53 primary.
(2, 18, 8, 1)
(5) Cabarrus

1982 House .12 .48 (2, 9, 8, 2) 1982 House .17 .54

<1, «, 4, 1) 1978 Senate .14 .31 (1, 5, 4, 0) 1978 Senate .15 .37 Polk loses in
(1, 5, 4, 0) 1980 Senate .09 .37 1982 Cabarrus

(1, 7, 4, 0) 1982 Senate .18 .27 (1, 6, 4, 0) 1982 Senate .16 .38 primary

(6) Durham
(1. 4, 2, 0) 1978 Senate .12 .03

(Rep. R)
(1, 3, 3, 1) 1978 House .28 .36 (2, 7, 3, 1) 1978 House .10 .99
U, 3. 3, 1) 1980 House .82 .35 No Primary 1980 House X X
(1, 4, 3, 1) 1982 House .20 .78 (2, 4, 3, 1)' 1982 House .35 .91

(7) Forsyth
(2, !), 5, 0) 1978 House .16 .34 (3, 10, 5, 1) 1978 House .14 .63

(1 Rep B) (1, 3, 2, 0) 1980 Senate .07 .51
(1, 10, 5, (I) 1980 House .07 .24 (2, 7, 5, 1) 1980 House .15 .55
(2, 8, 5, 2) 1982 House .21 .55 (2, 11, 5, 2) 1982 House .15 .55

Ex-8

TABLE 3 (continued)

GENERAL

(5) Wake
(1, 13, 0, 1) 1980 House
(1, 17, (>, 1) 1982 House

(3) E-W-N

(5) Edgecombe

1982 County
(2, 4, 3, 2) Commissioner

(4) Wilson

PRIMARY
candidate(s) candidate(s)

P'1 Wl! P'.m l"wn P'nu P'.m

.09 .19 (1, 12, 0, 0) 1978 House .05 .40

.09 .18 (1, 9, 0, 1) 1980 House .09 .50
(1, 15, 0, 1) 1982 House .10 .41

1982 House
1982 1st Cong-

(1, 7, 4, 0) .01 .36

Primary
1982 2nd Cong-

0 , 3, 2, 1) .02 .90

Primary (1, 2, 1, 0) .05 .94

1982 House
1982 1st Cong-

(1, 7, 4, 0) .01 .31

Primary
1982 2nd Cong-

(1, 3, 2, 1) .02 .92

Primary (1, 2, 1, 0) .02 .99
1982 County

.40 .08 Commissioner (4, 10, 3, 2) .02 .87

1982 House
1982 1st Cong-

(1, 7, 4, 0) .01 .52

Primary
1982 2nd Cong

(1, 3, 2, 0) .07 .98

Primary (1, 2, 1, 0) .07 .99
1970 County

Commissioner (1, 13, 7,0) .05 .30

Michaux wins
in Edgecombe
only

Ex-9

TABLE 3 (continued)

PRIMARY
candidate(s) candidate(s)

197(5 House
1982 1st Cong-

(1, 7, 4, 0) .01 :3l

Primary
1982 2nd Cong-

a . a, 2, i) .07 .79

Primary
1982 County

(1, 2, 1, 0) .0(5 .82

Commissioner (1,0, 3, 0) .04 .49

*In Edgecombe, Wilson and Nash there was only black candidate for House or Senate in the period 11)78-11)82. Data for those counties are based in addition on a 197(5 County Commission race in
Wilson, 1982 Congressional Primaries, and Edgecombe and Nash 1982 County Commission Primaries and General Elections.

N - 58
Actual district races - MO House & Senate (P&G)

•1 County Commissioner (P&G)
2 Cong Primaries

Ex-10

PLAINTIFF’S EXHIBIT 11, APP. 6#4 Gingles

APPENDIX 6 to “Effects Multimember Districts”
Black Legislative Representation in States with Black Population over 15%

Percent
Predominantly single
member districts in areas # of Black

Predominantly single
member districts in areas # of Black

Predominantly single
member districts in areas

population of Black concentration as Reps, in of Black concentration as Reps, in of Black concentration as
Black (1970) of July 1977 July 1977 of July 1982 July 1982 of July 1983

Alabama 26.4 YES 15 YES 16 YES
Arkansas 18.6 NO 4 NO 5 NO
Florida 15.5 NO 3 NO 5 YES
Georgia 25.9 YES 23 YES 22 YES
Louisiana 29.9 YES 10 YES 13 YES
Maryland 17.9 * 19 * 21 **
Mississippi 36.8 NO 4 YES 17 YES
North Carolina 22.4 NO 6 NO 4 YES & NO
South Carolina 30.5 YES 13 YES 15 YES
Tennessee 16.1 YES 11 YES 12 YES
Virginia 18.6 NO 2 NO 5 NO

# of Black
Reps, in
July 1983

20
5

12
24
13
23
17
13
20
13

1977 (omitting Maryland) 1982 (omitting Maryland) 1982 (omitting N.C. & Maryland)
Average # of Black Representatives in States with
Predominantly Single Member Districts in Black Areas 3.8 (TOTAL — 19, N = 5) 4.8 (TOTAL - 19, N 4) (i (TOTAL = 12, N = 2)

Average # of Black Representatives in States with
Predominantly Single Member Districts in Black Areas 14.5 (TOTAL — 72, N — 5) 15.8 (TOTAL - 95, N — 0) 18.4 (TOTAL ~ 129, N — 7)

*:> member districts used throughout, Blacks only elected from majority Black mmds.
**mix of 1, 2, and .'» person districts, Blacks only elected from majority Black mmds and smds, with one exception

Ex-11

Success in General Elections
Wo o f candidates th at Lose by party race)

1910-1982 „„„ 1982
fetlOOtyo

W B W B
Democrats Republicans

100
9 0
s o
TO
60
50
AO
30
20
10
0

2 ^ V - 5 ° T o

O ~ 0 ° l o

2 = 2 8 .5 7 o

1 N /A
W B W B

Democrats Republicans

Exhibits

Ex-12

Participation in General Elections
1% o f candidates o f each p arty by race)

1970-1982
I 5 8 ” % 5 %

B W B
Democrats Republicans

1982
2 b H < ? 0 %

W B W B
Democrats Republicans

E X H I B I T 1 9

Gingles

Ex-13

Ex-14

PLAINTIFF’S EXHIBIT 20 GINGLES
The Disadvantageous Effects of At-Large Elections

On the Success of Minority Candidates
For the Charlotte and Raleigh City Councils

Bernard Grofman
Professor of Political Science
School of Social Sciences
University of California, Irvine
Irvine, California

May 20, 1983

I. Campaign Expenditures in the District-Based
and At-Large Component of the Charlotte City Council and

Raleigh City Council Elections in 1979 and 1981

We would like to test the hypothesis that at-large elec
tions are more expensive to run than district-based cam
paigns. Intuitively it would seem very reasonable that at-
large elections, involving as they do larger constituen
cies, would be more costly.1 However, there are a number
of methodological problems in empirically validating what
might appear commonsensically obvious; even though the
few available studies (e.g., Grofman 1982; Jewell 1982) all
support the truth of the proposed hypothesis:

(1) There are differences in spending patterns between
incumbents and non-incumbents. Moreover, those differ
ences are complicated by the considerable incumbency
advantage in raising money versus the countervailing
lesser need of highly visible incumbents to spend money
to win elections. Also the magnitude of the incumbency

1 Campaign funds are often spent somewhat differently in at-large
than in district elections; for the latter, use of city-wide media (e.g.,
radio, TV, city newspapers) is less efficient than for the former and
this may reduce somewhat the cost advantages produced by the
smaller scope of district-based campaigns.

Ex-15

advantage is often different in at-large than in single
member district elections.

(2) Both at-large and district races contain candidates
who run with little chance of victory (and with minimal
campaign expenses), but the number of such candidates is
generally greater in at-large elections.

(3) Many candidates largely finance city council cam
paigns through their own funds, and such personal re
sources vary widely, introducing idiosyncratic features
which are hard to control for because of the small number
of mixed system elections for which we have campaign
funding data available for analysis.

Nonetheless, each of these methodological problems
associated with analyzing comparative campaign expen
ditures across different types of election systems may be
solved (or at least mitigated) if (1) we distinguish between
incumbent and non-incumbent expenditures (2) for both
incumbents and non-incumbents we focus on the expendi
tures of the winning candidates, and (3), we combine data
so as to obtain a larger sample size and more reliable data
estimates. We shall look at Charlotte City Council and
Raleigh City Council campaign expenditures patterns,
combining 1979 and 1981 data.

In Charlotte there were four at-large seats and seven
district seats in both the 1979 and 1981 elections (see
Appendices 1 and 2). Combining data for the two elections
we find winners at large averaged over $12,000 on cam
paign expenditures (whether they were incumbent or
non-incumbent); while in the district based elections, win
ning challengers spent ony $5,815 and winning incum
bents spent only $3,198 (see Table 1). Thus, campaign
costs in Charlotte City Council at-large elections were, on
average, more than twice those for district elections in
that city.

Ex-16

In Raleigh, for both the 1979 and the 1981 election,
there were two at-large seats and five district seats (see
Appendices 3 and 4). Combining data for the two elections
we find incumbent winners at-large spent an average of
$9,105 while incumbent district winners spent an average
of only $5,344; non-incumbent at-large winners spent an
average $11,925 while non-incumbent district winners
spent on average only $5,213. Thus, at-large campaign
costs in Raleigh at-large city council elections were, on
average, roughly twice those for district elections in that
city.

II. Success of Black Candidates in the District-Based
and At-Large Component of Charlotte City Council

and Raleigh City Council Elections

The considerably higher expenditures required to run a
successful at-large race in Charlotte imposes a burden on
minority groups (such as blacks) who are economically
disadvantaged. This financial burden, combined with ra
cial bloc voting which makes for a greater difficulty of
black success in at-large race with a primarily white elec
torate as compared to a district race with a primarily
Black electorate (e.g., Charlotte Districts 2-3), has meant
that Blacks are disproportionately excluded from the at-
large council seats in Charlotte. In the period 1977-1981,
of the 21 district seats contested, Blacks won 6 (28.6%);
while of the 12 at-large seats contested Blacks won only 2
(16.7%), despite the fact that there were more Black
candidates for the four at-large seats than for the seven
district seats. In the preceding period, 1945-1975, under
a pure at-large system, Black representation was even
less, averaging only 5.4% (Heilig and Mundt 1981; see also
Heilig, 1978; Mundt 1979).

As in Charlotte, Black electoral success in Raleigh was
considerably greater in the district than in the at-large
component of the city council elections in 1977-1981. Of

Ex-17

the 15 district seats contested, Blacks won three (20.0%),
while of the six at-large seats contested, Blacks won no
seats (0.0%), despite the fact that there were propor
tionally about as many Black candidates contesting the at-
large elections as contesting the district elections. This
finding of greater minority success in a district-based
system (or the district-based component of a mixed sys
tem) than under an at-large or multi-member district
system has been repeated in a large number of munici
palities and other jurisdictions where there exists a sub
stantial minority population and patterns of polarized
voting (see esp. Engstrom and McDonald 1981; Karnig
and Welch 1978,1979; Grofman 1981; and overviews of the
literature in Engstrom and McDonald 1984 forthcoming
and in Grofman 1982b).

“Indeed, few generalizations in political science ap
pear to be as well verified as the proposition that at-
arge elections tend to be discriminatory toward

black Americans” (Engstrom and McDonald, 1984
forthcoming).

III. Summary

We examined the campaign expenditure patterns for
the at-large and district components of Charlotte and
Raleigh, North Carolina city council elections and found
that successful at-large election campaigns are more ex
pensive to run than successful district compaigns. We
then looked at the success of black candidates in recent
Charlotte and Raleigh city council races and found dra
matically greater success for black candidates running in
the district-based elections than for those running for the
city-wide seats. In reducing their likelihood of obtaining
office if they do seek it, and/or in increasing the amount of
money which must be spent to achieve office, at-large
elections in Charlotte and Raleigh had a discriminatory
effect on Black candidates, when compared with district
elections in the same cities.

Tahiti'
Campaign Expenses: Charlotte City Council, 1979-1981

Winning Incumbents2
dartre District

$12,194 (N = 12) ,198 (N = 9)

Winning Non-Incumbents
At-large District

1979
expenditures

average (N = 2)

$5,700
4,945

$5,326

$ 554
1,084
1,907
2,699
5,784
2,914
5,075

$3,031

(N = 2)

(N = 5)

$18,142
19,100

$18,021

None

Winning Incumbents Winning Non-Incumbents
At-large District At-large District

$3,119 $7,014 $8,717
1,936 5,292 2,913

1981 2,777 average $0,153 (N = 2) $5,815

expenditures $18,452 4,531 (N = 2)
19,009 4,800

average (N = 2) $19,001 (N = 5) $3,433 (N = 5)

Winning Incumbents Winning Non-Incumbents
At-large District At-large District

1979 and average
1981 (N = 1)
combined
* There were not enough winning blank candidates to make it feasible to separately tabulate by race of candidate. The raw data on which this
research note.

-In liffil and l'lfil all incumbents running for reelection to the Charlotte City Counity won reflection. In 1SI7!) » of 11 incumbents sought

$12,287 (N = 2) $5,815

table was based Is provided as appendices to this

reflection; in 1981, 7 of 11 did.

Ex-18

Tablet2
Campaign Expenses: Raleigh City Council, 1979-1981

Winning Incumbents Winning Non-Incumbents

1979
expenditures

average (N = l)

At-large District At-large District

$3,598
$3,598

$15,723
4,187

257
5,048

$ 6,304
$10,016
$10,016

ItOOl OO
€/3-

Winning Incumbents Winning Non-Incumbents
At-large District At-large District

1981 $5,310
expenditures $14,611 1,301 $13,834 $1,463

average ( N=l ) $14,611 (N = 4) $4,383 (N = 1) $13,834 (N = 1) $1,463

Winning Incumbents Winning Non-Incumbents
At-large District At-large District

1979 and
1981 average $9,105 (N = 8) $5,344 (N = 2) $11,925 <N = 2) $5,213
combined (N 2)
•There were not enough winning black candidates to make it feasible to separately tabulate by race of candidate. The raw data on which this table was based is provided as appendices to this
research note.

Ex-19

Ex-20

N.
J

W 1 I 1 T 1 P E O P L E

WAKEUP
&EFO«E I T 'J T O O LATE

YOUM AYNOT MZVS ANOTM m CMANCB

DO YOU WANT?

PLAINTIFF'S
EXHIBIT

25
G i r d l e s

Negroes working beside you, your wife ond daughters in your
mills and factories?

Negroes eating beside you in alT public eotmg places?
Negroes riding beside you, yoiir wife and your daughters in

buses, cabs and trains?
Negroes sleeping in the same hctels pry) rooming houses?
Negroes teaching and disciplining your children in school?
Negroes sitting with you and your family at all public meetings?
Negroes Going to white schools and white children oping to Negro

schools? *
Negroes to occups the some hospital rooms with you and vour

wde and daughters? i
Negroes as sour foremen and overseers in the mills?
Negroes using vour toilet facilities?

Northern political labor leaders here recently ordered thet
ell doors be opened to Negroet on union property. This will
lead to whites ond Negroes working ond tiring together in
the South es they do in the North, Do you want that?

FRANK GRAHAM FAVORS MINGLING OF THE RACES
HI ADMITS THAT HI FAVORS MIXING NIGROIS AND WHITIS — HI SAYS SO IN
TH I RtPORT HI SIGNID. (Far Proof of This, Used Page 167, Ciril Rights Report.)

DO YOU FAVOR THIS — WANT SOME MORE OF IT?
IF YOU DO, VOTE FOR FRANK GRAHAM

■ U T IF Y O U D O N ' T

V O T E FOR AND HELP E L E C T

w m i s m r m i©? s e b m h o b
HE WILL UPHOLD THE TRADITIONS OF THE SOUTH

KNOW THE TRUTH COMMITTEE

Ex-21

300

Number
o f Black
Elected
Officials

Years (1970- 1981)
Number o f Black Elected Officials

in North Carolina (1970 "L98D
G ingles

Ex-22 Exhibit,41

Ex-23

PLAINTIFF’S EXHIBIT
52

Gingles

For Congress
Dear Fellow Democrat:

Tuesday, July 27th is a very important day for Democrats in
Durham County. It is a day when you have a chance and
obligation to influence the direction in which our national
government w ill move during the critical years ahead.

That choice is whether you want to be represented in Congress by
a big-government, free-spending liberal, or whether you want to
be represented by a person whose thinking is much more in tune
with the majority of our people.

I think the choice is very clear.

My opponent's liberal record is well-known.

While serving in the state legislature, among other things, he
sponsored a bill which would have raised your personal income
taxes by as much as 40 percent.

He also sponsored a bill which could have forced you to pay
dues to a labor union whether you wanted to or not.

I am opposed to hjs kind of liberal thinking and I believe the
majority of the people in our district are too.

Ex-24

I want you to know that I am opposed to higher taxes, i plan to
introduce a constitutional amendment which would require a
balanced federal budget, which would force the government to
live within its means.

That would cause interest rates to come down which would revive
agriculture, help industry grow and create more jobs for our
people, thereby bringing down unemployment.

I have also made a commitment to open a fully-staffed
Congressional Office in Durham, so that you w ill never be more
than a local phone call away from help with your problems with
the Federal Government.

I know it's July and it's hot. Many folks are on vacation. Many are
busy with tobacco. It's easy not to stop and take the time to vote,
but you must.

Our polls indicate that the same well organized block vote which
was so obvious and influential on the 1 st Primary w ill turn out
again on July 27. My opponent w ill again be bussing his
supporters to the polling places in record numbers.

If you and your friends don't vote on July 27 my opponent's block
vote w ill decide the election for you.

A Congressm an We Can Be Proud Of
Paid for by the Tim Valentine for Congress Committee.

C.T. Lane, Treasurer, P.O. Box 353, Rocky Mount, N.C. 27801
A copy of our report is filed with the Clerk of the House and is

available for purchase from The Federal Election Commission,
Washington, D.C. 20515

Ex-25

Your vote w ill make the difference.

Please join me in voting on Tuesday, July 27. I promise to be a
Congressman of whom you can be proud.

Sincerely,

Tim
Valentine

P.S. CALL TO ACTION

Please take the time to become personally involved in my
campaign by listing below the names of five friends and
neighbors, along with their telephone numbers, and call them on
Tuesday, July 27 to make sure that each one votes.

NAME TELEPHO N E #

Valentine
For Congress

Ex-26

For Congress
Durham Headquarters
202 Corcoran Street
Durham, N.C. 27701

July 21, 1982

Dear Registered Voter,

We ask that you consider the voting pattern and
results of the June 29 primary. There were many many
precincts in Durham that voted over 60% of their
registration, while our precinct only voted around 45%.

If you object to this domination-—if you are
resentful of having others elect your officials—then you
should vote on July 27.

Join us in proving to ourselves that Tim Valentine
can carry Club Boulevard precinct.

Regards,

Jim Dickson

Ex-27

From the Durham Morning Herald

June 50, 1982

Precinct Valentine Michaux Ramsey

Club Blvd. 264 209 282
Burton 9 1260 14
Hillside 1 883 9
Whitted 1 419 5
Shepard 2 744 9
Hillandale 302 192 313

A Strong Voice Fo r Our D istric t
Paid for by the Tim Valentine for Congress Committee.

C.T. Lane, Treasurer, P.O. Box 353, Rocky Mount, N.C. 27801
A copy of our report is filed with the Clerk of the House and is
available for purchase from The Federal Election Commission,

Washington, D.C. 20515

Ex-28

DEFENDANT’S EXH IBIT 1

STATE BOARD OF ELECTIONS
Suite 801 R a l e ig h B u ild in g

5 W est H a r g e t t St r e e t
R a l e ig h , North Ca r o l in a 27601

ROBERT W. SPEARMAN
Chairman

Members

MRS. ELLOREE M. ERWIN
Charlotte

WILLIAM A. MARSH, JR.
Durham

MRS. RUTH TURNER SEMASHKO
Horse Shoe

ROBERT W. SPEARMAN
Raleigh

JOHN A. WALKER
North Wilkeshoro

November 30, 1981

SPECIAL MEMORANDUM
SUBJECT: Increased Voter Registration

FROM: Robert W. Spearman, Chairman
Alex K. Brock, Director

TO: All County Board Members and Supervisors

At its meeting on November 9, 1981, the State
Board of Elections adopted and endorsed the goal of
increased voter registration in North Carolina as a top Board
priority.

The Board has directed us to communicate with
each of you about its interest and concern in this important
area.

A successful effort to increase voter registration
will require pooling the efforts, talents, energy and ideas of

Ex-29

local board members, supervisors, elected officials, state
board members and staff with the political parties, civic
groups and all interested citizens.

We would request that at your next local board
meeting you consider what specific steps can be taken in
your county and statewide to make it easier and more
convenient for citizens to register to vote. We also request
you provide our board with the voting age population in your
county, based on the most recent U.S. census.

We would very much appreciate any guidance
and suggestions you can give us as to steps the state board
and its staff can take to increase registration, whether those
be by adopting or altering regulations, recommending
legislation to the General Assembly, sponsoring registration
drives or other techniques.

We are aware that certain voter registration
techniques work better in some areas than in others. Among
the approaches that you may wish to consider using in your
county are:

1. Running public service spots on TV or radio
telling citizens the specific times and places thay can
register.

2. Encourage local political parties to work with
precinct judges, registrars and special registration commis
sioners to have special voter registration days at community
centers, schools and shopping centers.

3. Request local county (and municipal) officials
to include information about how and where one can register
in mailings that are routinely sent out from county or city
offices (e.g., with tax listing notices, water and sewer bills,
etc.).

4. In counties where such a system is not
already in place, work with local library officials and library
trustees to have public library employees designated as

Ex-30

special library registration deputies. (This is already autho
rized by G.S. 163-80 (6 ).)

5. Use supervisors, deputy supervisors of elec
tions and local election board members as registrars for
special registration efforts in schools, community centers,
nursing homes, etc. (This is already authorized by G.S.
163-35 and 163-80.)

We very much look forward to working with you
on voter registration and we would certainly appreciate any
suggestions you can pass along to us.

DUPLICATE THIS FOR ALL BOARD MEMBERS

Ex-31

DEFENDANT’S EXHIBIT 2

STATE BOARD OF ELECTIONS
Suite 801 R a l e ig h B u ildin g

5 W est H a r g e t t St r e e t
R a l e ig h , North Caro lin a 27601

ROBERT W. SPEARMAN
Chairman

Members

MRS. ELLOREE M. ERWIN
Charlotte

w il l ia m a . m a r s h . JR.
Durham

MRS. RUTH TURNER SEMASHKO
Horse Shoe

ROBERT W. SPEARMAN
Raleigh

JOHN A. WALKER
North Wilkesboro

December 14, 1981

TO: WORTH CAROLIWA COUWTY ELECTIONS BOARDS AND
SUPERVISORS

Recently questions have been raised, concerning com
pensation of registrars, judges and special registration
commissioners in voter registration efforts. Often the
questions have come up when a civic or community group
desires to have a qualified person eligible to register voters
present at a rally, picnic, dinner or some other community
occasion. In such situations, the following principles should
be followed.

1. Under State law any registrar, judge of election or
special registration commissioner can register voters any
where in the county without regard to the precinct of the
applicant unless the local board has restricted the authority
of the registrar, judge or special commissioner. G.S. 173-67.

The State Board strongly encourages the use of
registrars, judges and special registration commissioners for

Ex-32

special registration efforts and suggests that any local board
rules restricting their authority be reexamined.

2. There is no state law requirement that registrars,
judges or special registration commissioners be compensated
for registering voters. Frequently registrars and judges
register voters (as opposed to performing their election day
duties) on a volunteer basis without pay. (However, some
county boards do pay for special registration work performed
at public libraries or other places, and it is perfectly proper
to do so.)

3. Private groups may not compensate registrars,
election judges, or special registration commissioners. G.S.
163-275.

4. If a private group (e.g. civic club, community
association, etc.) is willing to or desires to reimburse a
county for the cost of paying registrars for special registra
tion efforts it may properly do so. The proper procedure to
follow is for the group to make a contribution to the board of
county commissioners for the purpose of special voter
registration and the commissioners could then appropriate
the funds to the local Board of Elections for such purpose.

Robert W. Spearman
Chairman, State Board of
Elections

Alex K. Brock
Executive Secretary-Director,
State Board of Elections

Senior Deputy Attorney General

DUPLICATE FOR ALL BOARD MEMBERS

Ex-33

DEFENDANT’S EXHIBIT 3

STATE BOARD OF ELECTIONS
Suite 801 R a l e ig h B u ildin g

5 W est Ha r g e t t St r e e t
Raleigh, North C a ro lin a 27601

ROBERT W. SPEARMAN
Chairman

Members

MRS. ELLOREE M. ERWIN
Charlotte

WILLIAM A. MARSH, JR.
Durham

MRS. RUTH TURNER SEMASHKO
Horse Shoe

ROBERT W. SPEARMAN
Rale i oh

JOHN A. WALKER
North Wilkesboro

January 29, 1982

TO: COUNTY BOARD MEMBERS ANT) SUPERVISORS

FROM: BOB SPEAR MATT, CHAIRMAN
ALEX BROCK, EXECUTIVE DIRECTOR

SUBJECT: CITIZEN AWARENESS YEAR AND VOTER
REGISTRATION

At the request of the State Board of Elections,
Governor James Hunt has designated 1982 as a Citizen
Awareness Year in which a maximum effort will be made to
increase North Carolina voter registration.

The State Board will sponsor two major voter
registration drives, from April 15, 1982 to July 5, 1982
before the primary and from September 1 to October 4
(when registration closes for the general election.)

The voter registration drive is officially spon
sored and is nonpartisan. All political parties and civic
groups are invited and encouraged to participate.

Ex-34

Obviously, the success of this effort will depend
very much upon you because you are the public officials most
familiar with the election process and closest to its day-to-
day operation.

There will be two main thrusts to the voter
registration drive: (1 ) Maximum publicity of existing voter
registration opportunities and (2 ) Provision of special
registration opportunities to maximize participation.

The State Board intends to take all possible steps
to maximize statewide publicity, including holding press
conferences and providing public service spots to radio and
television stations. We request that your local board take
similar steps in your county or municipality. Specifically, you
may wish to consider the following:

Check with local T.V. and radio stations to
determine if they will produce and broadcast public service
spots telling county citizens when and where they can
register to vote. (The spot announcements can be made by
different board members.)

Issue press releases on Citizen Awareness Year
in your area and registration opportunities.

Post signs or notices with registration informa
tion in public places (e.g. county offices, stores, community
bulletin boards.)

Check with county and municipal officials to see
if they would agree to have basic voter registration informa
tion included with routine official mailings (e.g. with tax
notices or municipal water bills.)

Special Registration Opportunities.

In addition to publicizing existing registration
opportunities, we need to take extra steps to reach groups
whose registration has historically been low. Situations vary
in different areas of the State, but frequently groups with low
registration include elderly citizens, young people, and

Ex-35

minority groups. We request you consider using the following
outreach techniques during Citizen Awareness Year, particu
larly from April 15, 1982 to July 5, 1982 and September 1 to
October 4, 1982.

1. Staff registration tables in evening hours at
places where large groups of people congregate (shopping
centers are often excellent.)

2. Have a “registration day” in the spring and
again in the fall in local public high schools and community
colleges; on these days send registrars and commissioners to
register students and faculty at their educational institutions.

3. Send registrars or commissioners for special
registration events to residential areas where registration is
low. These may include nursing homes, public housing or
mobile home parks.

4. Upon request; supply registrars or commis
sioners for special events being run by community groups,
such as banquets, dinners, picnics, athletic contests, church
suppers, etc. (Very frequently, this can be done without any
cost to the board because registrars or commissioners will
donate their time and not expect to be paid.)

We expect that local boards will receive requests
from political parties and community groups for assistance
in special registration efforts during Citizens Awareness
Year.

When you receive such requests, try to be as
helpful as you can in answering questions, supplying voter
registration information and where necessary, helping to
find registrars, judges, and special registration commis
sioners who can assist in registering voters at special
events.

Paid Pol. Adv.

W H A T NORTH CAROLINA NEWSPAPERS
SAY A B O U T VOTER REGISTRATION

GOV. H U N s, REV . JACKSON M E E T — Governor Jim Hunt and the Rev.
Jesse Jackson met in the Executive Mansion March 11 to discuss a number of
mutual concerns, including voter registration . . .

T h e C a r o l in i a n , 3 - 1 8 - 8 2

“ He (Jesse Jackson) said Gov. Jim Hunt, an expected
Senate candidate in 1984, had fa limited future— unless
we register/ * *

Greensboro Daily N e w s . 5 - 76-83

"W e must register at least 200,000 black voters in North
Carolina in the next two months." (Jesse Jackson)

News a n d O b s e r v e r , 4 -2 2 -3 3

"Gov. James B. Hunt, Jr. wants the State Board of
Elections to boost minority voter registration in
North Cuiolina . . . L PI Chapel Hill Newspaper, 11-10-81

Ask Yourself:
Is This A Proper Use Of Taxpayer Funds?

fW 6r Sw*#* v -— ••••

Ex-36

Ex-37

GINGLES EXHIBIT #56

Mecklenburg County— Demographic Data

White Black Total
Population 291,442 107,006 404,270
Percent of Population 72.1 26.5

Percent of Population Below
Poverty 5.5 25.7 10.9

Percent of Family Income
over $20,000 61.7 27.9 53.6

Mean Income 27,209 15,519 24,462
Ratio Black to White Mean

Income 57.0%

Total Number of Housing
Units 111,223 34,209

Number of Renter Occupied 36,949 2,056
Percent Renter Occupied 33.2 60.1
Percent Units with No Vehi

cle Available 5.0 26.5 10.0

Percent Over 25 with
Eighth Grade Education
or Less 9.9 25.0

Percent Voting Age Popula
tion that is Black (1980) 24.0

Percent Voters that is Black
(1980) 16.9

Ex-38

GINGLES EXHIBIT #57

Forsyth County— Demographic Data

White Black Total
Population 182,647 59,403 243,683
Percent of Population 75.0 24.4

Percent of Population Below
Poverty

Percent of Family Income
6.9 25.6 11.6

over $20,000 56.2 28.6 50.2
Mean Income
Ratio Black to White Mean

25,355 15,101 23,188

Income 59.56%

Total Number of Housing
Units 69,699 19,885

Number of Renter Occupied 19,320 11,934
Percent Renter Occupied
Percent Units with No Vehi-

27.7 60.0

cle Available 5.9 27.4 10.7

Percent Over 25 with
Eighth Grade Education
or Less 16.7 26.6

Percent Voting Age Popula
tion that is Black (1980) 22.0

Percent Voters that is Black
(1980) 20.3

Ex-39

GINGLES EXHIBIT #58

Durham County— Demographic Data

White Black Total
Population 95,818 55,424 152,785
Percent of Population 62.7 36.3

Percent of Population Below
Poverty 7.6 24.9 14.0

Percent of Family Income
over $20,000 57.8 28.5 47.9

Mean Income 24,984 15,357 21,719
Ratio Black to White Mean

Income -61.47%

Total Number of Housing
Units 36,792 18,343

Number of Renter Occupied 13,953 11,462
Percent Renter Occupied 37.9 62.5
Percent Units with No Vehi

cle Available 6.9 25.2 13.0

Percent Over 25 with
Eighth Grade Education
or Less 14.6 26.6

Percent Voting Age Popula
tion that is Black (1980) 33.6

Percent Voters that is Black
(1980) 24.9

Ex-40

GINGLES EXHIBIT #59

Wake County—Demographic Data

White Black Total
Population 231,561 65,553 301,327
Percent of Population 76.8 21.8

Percent of Population Below
Poverty 6.2 23.4 10.0

Percent of Family Income
over $20,000 63.7 28.7 56.8

Mean Income 26,893 15,347 24,646
Ratio Black to White Mean

Income 57.07%

Total Number of Housing
Units 85,664 19,793

Number of Renter Occupied 29,609 11,021
Percent Renter Occupied 34.6 55.7
Percent Units with No Vehi

cle Available 4.5 21.0 7.6

Percent Over 25 with
Eighth Grade Education
or Less 9.3 28.2

Percent Voting Age Popula
tion that is Black (1980)

Percent Voters that is Black
(1980)

Ex-41

GINGLES EXHIBIT #60

Wilson County— Demographic Data

White Black Total
Population 39,943 22,981 63,132
Percent of Population 63.3 36.4

Percent of Population Below
Poverty 9.6 37.8 20.0

Percent of Family Income
over $20,000 45.5 17.1 36.5

Mean Income 21,687 12,241 18,732
Ratio Black to White Mean

Income 56.44% 14.0

Total Number of Housing
Units 14,725 6,781

Number of Renter Occupied 4,818 4,368
Percent Renter Occupied 32.7 64.4
Percent Units with No Vehi

cle Available 7.1 29.1 14.0

Percent Over 25 with
Eighth Grade Education
or Less 23.0 44.2

Percent Voting Age Popula
tion that is Black (1980) 32.4

Percent Voters that is Black
(1980) 23.0

Ex-42

GINGLES EXHIBIT #61

Edgecombe County— Demographic Data

White Black Total
Population 27,428 28,433 55,988
Percent of Population 49.0 50.8

Percent of Population Below
Poverty 9.6 30.5 20.2

Percent of Family Income
over $20,000 44.2 20.2 33.3

Mean Income 20,476 13,592 17,360
Ratio Black to White Mean

Income -66.38%

Total Number of Housing
Units 10,246 8,117

Number of Renter Occupied 2,782 4,258
Percent Renter Occupied 27.2 52.5
Percent Units with No Vehi

cle Available 7.7 26.2 16.0

Percent Over 25 with
Eighth Grade Education
or Less 23.8 40.3

Percent Voting Age Popula
tion that is Black (1980) 46.7

Percent Voters that is Black
(1980) 34.6

Ex-43

GINGLES EXHIBIT #62

Nash County— Demographic Data

White Black Total
Population 44,745 22,089 67,153
Percent of Population 66.6 32.9

Percent of Population Below
Poverty 8.9 41.8 19.9

Percent of Family Income
over $20,000 46.7 13.9 37.5

Mean Income 21,785 11,434 18,937
Ratio Black to White Mean

Income 52.49%

Total Number of Housing
Unifs 16,982 6,391

Number of Renter Occupied 4,933 3,763
Percent Renter Occupied 29.0 58.9
Percent Units with No Vehi

cle Available 6.7 27.2 12.3

Percent Over 25 with
Eighth Grade Education
or Less

Percent Voting Age Popula
tion that is Black (1980) 29.4

Percent Voters that is Black
(1980) 13.2

Ex-44

GINGLES EXHIBIT #63

Halifax County— Demographic Data

Population
Percent of Population

Percent of Population Below
Poverty

Percent of Family Income
over $20,000

Mean Income
Ratio Black to White Mean

Income

Total Number of Housing
Units

Number of Renter Occupied
Percent Renter Occupied
Percent Units with No Vehi

cle Available

Percent Over 25 with
Eighth Grade Education
or Less

Percent Voting Age Popula
tion that is Black (1980)

Percent Voters that is Black
(1980)

White
27,559

49.8

Black
26,053

47.1

Total
55,286

12.6 47.8

37.9
19,042

12.9
10,465

27.1
15,479

-54.96%

10,680
2,800
26.2

7,201
3,520
48.9

10.2 32.3 19.0

25.6 51.5

44.0
35.2

Ex-45

GINGLES EXHIBIT #64

Northampton County— Demographic Data

White Black Total
Population 8,824 13,709 22,584
Percent of Population 39.1 60.7

Percent of Population Below
Poverty 11.6 38.2 28.1

Percent of Family Income
over $20,000 34.9 15.3 24.0

Mean Income 19,964 12,942 16,080
Ratio Black to White Mean

Income 64.83%

Total Number of Housing
Units 3,248 3,849

Number of Renter Occupied 549 1,261
Percent Renter Occupied 16.9 32.8
Percent Units with No Vehi

cle Available 10.5 27.9 19.9

Percent Over 25 with
Eighth Grade Education
or Less 23.1 54.6

Percent Voting Age Popula
tion that is Black (1980) 56.2

Percent Voters that is Black
(1980) 51.4

Ex-46

GINGLES EXHIBIT #65

Hertford County— Demographic Data

Population
Percent of Population

Percent of Population Below
Poverty

Percent of Family Income
over $20,000

Mean Income
Ratio Black to White Mean

Income

Total Number of Housing
Units

Number of Renter Occupied
Percent Renter Occupied
Percent Units with No Vehi

cle Available

Percent Over 25 with
Eighth Grade Education
or Less

Percent Voting Age Popula
tion that is Black (1980)

Percent Voters that is Black
(1980)

White
10,285

44.0

Black
12,810

54.8

Total
23,368

10.4 34.7 24.3

41.8
20,465

20.5
13,194

31.2
16,946

64.47%

3,727
950

25.5

3,709
1,452
39.1

10.0 28.1 19.2

21.9 48.1

56.2

51.4

Ex-47

GINGLES EXHIBIT #66

Gates County— Demographic Data

White Black Total
Population 4,192 4,664 8,875
Percent of Population 47.2 52.6

Percent of Population Below
Poverty 7.9 30.5 19.7

Percent of Family Income
over $20,000 43.4 22.1 33.4

Mean Income 21,025 13,204 17,380
Ratio Black to White Mean

Income -62.8%

Total Number of Housing
Units 1,605 1,274

Number of Renter Occupied 265 343
Percent Renter Occupied 16.5 26.9
Percent Units with No Vehi

cle Available 7.2 21.9 13.7

Percent Over 25 with
Eighth Grade Education
or Less 21.3 43.4

Percent Voting Age Popula
tion that is Black (1980) -49 .4

Percent Voters that is Black
(1980) 47.8

Ex-48

GINGLES EXHIBIT #67

Martin County— Demographic Data

White Black Total
Population 14,334 11,555 25,948
Percent of Population 55.2 44.5

Percent of Population Below
Poverty

Percent of Family Income
10.8 40.3 24.1

over $20,000 * * *

Mean Income
Ratio Black to White Mean

* * *

Income -ijc

Total Number of Housing
Units *

Number of Renter Occupied
Percent Renter Occupied
Percent Units with No Vehi-

>fc

cle Available *

Percent Over 25 with
Eighth Grade Education
or Less 25.2 47.9

Percent Voting Age Popula
tion that is Black (1980)

Percent Voters that is Black 40.6
(1980) 33.1

*not available

Ex-49

GINGLES EXHIBIT #68

Bertie County— Demographic Data

White Black Total
Population 8,488 12,441 21,024
Percent of Population 40.6 59.2

Percent of Population Below
Poverty 13.2 40.7 29.4

Percent of Family Income
over $20,000 32.0 12.8 22.0

Mean Income 17,649 12,502 15,008
Ratio Black to White Mean

Income 70.8%

Total Number of Housing
Unite 3,346 3,533

Number of Renter Occupied 678 1,293
Percent Renter Occupied 20.3 36.6
Percent Units with No Vehi

cle Available 8.8 24.2 16.6

Percent Over 25 with
Eighth Grade Education
or Less 28.8 45.1

Percent Voting Age Popula
tion that is Black (1980) 54.5

Percent Voters that is Black
(1980) 44.2

Ex-50

GINGLES EXHIBIT #69

Washington County— Demographic Data

White Black Total
Population 8,346 6,410 14,801
Percent of Population 56.4 43.3

Percent of Population Below
Poverty 10.9 35.9 21.7

Percent of Family Income
over $20,000 48.5 22.4 38.9

Mean Income 20,868 13,019 17,998
Ratio Black to White Mean

Income 62.39%

Total Number of Housing
Units 3,052 1,670

Number of Renter Occupied 596 624
Percent Renter Occupied 19.5 37.4
Percent Units with No Vehi

cle Available 7.6 30.1 15.6

Percent Over 25 with
Eighth Grade Education
or Less 22.2 43.9

Percent Voting Age Popula
tion that is Black (1980) 39.1

Percent Voters that is Black
(1980) 34.0

Ex-51

GINGLES EXHIBIT #70

Chowan County— Demographic Data

White Black Total
Population 7,294 5,210 12,558
Percent of Population 58.1 41.5

Percent of Population Below
Poverty 8.8 45.4 24.0

Percent of Family Income
over $20,000 41.5 9.5 29.1

Mean Income 20,622 10,704 16,877
Ratio Black to White Mean

Income 51%

Total Number of Housing
Units 2,765 1,559

Number of Renter Occupied 587 738
Percent Renter Occupied 21.2 47.3
Percent Units with No Vehi

cle Available 7.5 30.3 15.8

Percent Over 25 with
Eighth Grade Education
or Less 23.2 48.9

Percent Voting Age Popula
tion that is Black (1980) 38.1

Percent Voters that is Black
(1980) 31.2

Ex-52

GINGLES EXHIBIT #70A

North Carolina— Demographic Data

White Black Total
Population 4,460,570 1,319,054 5,881,766
Percent of Population 75.8 22.4

Percent of Population
Below Poverty 10.0 30.4 14.8

Percent of Family In
come over $20,000 43.8 21.5 39.2

Mean Income 21,008 13,648 19,544
Ratio Black to White

Mean Income 64.9%

Total Number of
Housing Units 1,624,372 391,379

Number of Renter
Occupied 442,060 191,925

Percent Renter
Occupied 27.2 49.03

Percent Units with No
Vehicle Available 7.3 25.1 10.8

Percent Over 25 with
Eighth Grade Educa
tion or Less 22.0 34.6

Percent Voting

Ex-53

DEFENDANT’S EXHIBIT 1

STATE BOARD OF ELECTIONS
Suite 801 R a l e ig h B uilding

5 W est H a r g e t t St r e e t
R a l e ig h , North Ca ro lin a 27601

ROBERT W. SPEARMAN
Chairman

Mkmhers

MRS. ELLOREE M. ERWIN
Charlotte

william A. MARSH, JR.
Durham

MRS. RUTH TURNER SEMASHKO
Horsk Shoe

ROBERT W. SPEARMAN
Raleigh

JOHN A. WALKER
North Wilkekhoro

November 30, 1981

SPECIAL MEMORANDUM

SUBJECT: Increased Voter Registration

FROM: Robert W. Spearman, Chairman
Alex K. Brock, Director

TO: All County Board Members and Supervisors

At its meeting on November 9, 1981, the State
Board of Elections adopted and endorsed the goal of
increased voter registration in North Carolina as a top Board
priority.

The Board has directed us to communicate with
each of you about its interest and concern in this important
area.

A successful effort to increase voter registration
will require pooling the efforts, talents, energy and ideas of

Ex-54

local board members, supervisors, elected officials, state
board members and staff with the political parties, civic
groups and all interested citizens.

We are aware that certain voter registration
techniques work better in some areas than in others. Among
the approaches that you may wish to consider using in your
county are:

1. Running public service spots on TV or radio
telling citizens the specific times and places thay can
register.

4. In counties where such a system is not
already in place, work with local library officials and library
trustees to have public library employees designated as

Ex-55

special library registration deputies. (This is already autho
rized by G.S. 163-80 (6 ).)

We very much look forward to working with you
on voter registration and we would certainly appreciate any
suggestions you can pass along to us.

DUPLICATE THIS FOR ALL BOARD MEMBERS

Ex-56

DEFENDANT’S EXHIBIT 2

STATE BOARD OF ELECTIONS
Suite 801 R a l e ig h B u ildin g

5 W est H a r g e t t St r e e t
R a l e ig h , North C aro lin a 27601

ROBERT W. SPEARMAN
Chairman

Memhers

MRS. ELLOREE M. ERWIN
Charlotte

WILLIAM A. MARSH, JR.
Durham

MRS. RUTH TURNER SEMASHKO
Horse Shoe

ROBERT W.. SPEARMAN
Raleigh

JOHN A. WALKER
North Wilkeshoro

December 14, 1981

TO: NORTH CAROLINA COUNTY ELECTIONS BOARDS AND
SUPERVISORS

Recently questions have been raised concerning com
pensation of registrars, judges and special registration
commissioners in voter registration efforts. Often the
questions have come up when a civic or community group
desires to have a qualified person eligible to register voters
present at a rally, picnic, dinner or some other community
occasion. In such situations, the following principles should
be followed.

The State Board strongly encourages the use of
registrars, judges and special registration commissioners for

Ex-57

special registration efforts and suggests that any local hoard
rules restricting their authority he reexamined.

2. There is no state law requirement that registrars,
judges or special registration commissioners he compensated
for registering voters. Frequently registrars and judges
register voters (as opposed to performing their election day
duties) on a volunteer basis without pay. (However, some
county hoards do pay for special registration work performed
at public libraries or other places, and it is perfectly proper
to do so.)

3. Private groups may not compensate registrars,
election judges, or special registration commissioners. G.S.
163-275.

Robert W. Spearman
Chairman, State Board of
Elections

Alex K. Brock
Executive Secretary-Director,
State Board of Elections

Senior Deputy Attorney General

DUPLICATE FOR ALL BOARD MEMBERS

Ex-58

STATE BOARD OF ELECTIONS
Suite 801 R a l e ig h B u ildin g

5 W est H a r g e t t St r e e t
R a l e ig h , North Ca ro lin a 27601

ROBERT W. SPEARMAN
Chairman

Members

MRS. ELLOREE M. ERWIN
Charlotte

WILLIAM A. MARSH, JR.
Durham

MRS. RUTH TURNER SEMASHKO
Horse Shoe

ROBERT W. SPEARMAN
Raleich

JOHN A. WALKER
North Wilkesboro

DEFENDANT’S EXHIBIT 3

January 29, 1982

TO: COUNTY BOARD MEMBERS ANT) SUPERVISORS

FROM: BOB SPEARMAN, CHAIRMAN
ALEX BROCK, EXECUTIVE DIRECTOR

SUBJECT: CITIZEN AWARENESS YEAR AND VOTER
REGISTRATION

The voter registration drive is officially spon

Ex-59

sored and is nonpartisan. All political parties and civic
groups are invited and encouraged to participate.

Obviously, the success of this effort will depend
very much upon you because you are the public officials most
familiar with the election process and closest to its day-to-
day operation.

Check with local T.Y. and radio stations to
determine if they will produce and broadcast public service
spots telling county citizens when and where they can
register to vote. (The spot announcements can be made by
different board members.)

Issue press releases on Citizen Awareness Year
in your area and registration opportunities.

Post signs or notices with registration informa
tion in public places (e.g. county offices, stores, community
bulletin boards.)

Special Registration Opportunities.

In addition to publicizing existing registration
opportunities, we need to take extra steps to reach groups

Ex-60

whose registration has historically been low. Situations vary
in different areas of the State, but frequently groups with low
registration include elderly citizens, young people, and
minority groups. We request you consider using the following
outreach techniques during Citizen Awareness Year, particu
larly from April 15, 1982 to July 5, 1982 and September 1 to
October 4, 1982.

1. Staff registration tables in evening hours at
places where large groups of people congregate (shopping
centers are often excellent.)

3. Send registrars or commissioners for special
registration events to residential areas where registration is
low. These may include nursing homes, public housing or
mobile home parks.

We expect that local boards will receive requests
from political parties and community groups for assistance
in special registration efforts during Citizens Awareness
Year.

Ex-61

DEFENDANT’S
EXHIBIT

North Carolina Voter Registration February,
1982-October, 1982

White Voters
Non-White

Voters All Voters
Registered Registered Registered

2/9/82 2,081,836 401,962 2,483,798
3/31/82 2,108,211 416,735
6/1/82 2,160,579 455,368
10/4/82 2,201,189 470.638 2,671,827
Absolute
Increase
2/9/82 to 6/1/82 78,743 53,406 132,149
% increase
2/9/82 to 6/1/82 3.7% 13.2% 5%
Absolute
Increase
2/9/82 to 10/4/82 119,353 68,676 188,029
% increase
2/9/82 to 10/4/82 5.7% 17% 7.5 %

Approximate Percent of Voting Age Population*
Registered

2/9/82 58.6%
6/1/82 61.7%
10/4/82 63.1%

*based upon February, 1982 population statistics.

Ex-62

Voter Registration Increases For Selected Counties From
February 1982 to October 1982

County

Increase
White

Registered
Voters

%
Increase

Forsyth 4,105 4%
Mecklenburg 6,493 4%
Wake 4,416 4%

Durham 2,246 5%
Nash 802 4%
Edgecombe 215 2%
Wilson 952 5%
Halifax 676 5%

Bertie 431 10%
Chowan 131 3%
Gates 141 6%
Hertford 456 9%
Martin 202 3%
Northampton 1,029 22%
Washington 195 4%

Increase
Non-White
Registered

Voters
%

Increase

Total %
Increase

All
Voters

2,880 13% 6%
2,896 9% 5%
2,292 11% 5%

3,565 21% 9%
1,620 37% 10%
3,310 54% 19%
2,193 46% 14%
2,507 36% 16%

1,126 32% 20%
223 14% 6%
451 21% 13%

1,143 31% 18%
539 16% 7%

1,903 42% 32%
403 18% 9%

Ex-63

DEFENDANT’S EXHIBIT 15

STATE BOARD OF ELECTIONS
Suite 801 R a l e ig h B u ildin g

5 W est H a r g e t t St r e e t
R a l e ig h , North Ca ro lin a 27601

ROBERT W. SPEARMAN
Chairman

Members

MRS. ELLOREE M. ERWIN
Charlotte

WILLIAM A. MARSH. JR.
Durham

MRS. RUTH TURNER SEMASHKO
Horse Shoe

ROBERT W. SPEARMAN
Raleigh

JOHN A. WALKER
North Wilkesboro

January 14, 1983

Governor James B. Hunt
State Capital
Raleigh, North Carolina

Lieutenant Governor James
Green

Legislative Office Building
Raleigh, North Carolina

Speaker Liston Ramsey
North Carolina House of

Representatives
Raleigh, North Carolina

Gentlemen and Senator Woodard:

In recent months the North Carolina Board of
Elections has given careful consideration to possible recom
mendations to you concerning the conduct and administra
tion of the election laws.

Representative J. Worth
Gentry

North Carolina House of
Representatives

Raleigh, North Carolina

Senator Wilma C. Woodard
North Carolina State Senate
Raleigh, North Carolina

Ex-64

We have received proposals from interested citizens,
political parties, county election boards and other groups.

We wish to recommend the following six items for
legislative action in the 1983 Session. As you are aware the
State board and County Boards have in the last year made
extensive efforts to ease access to voter registration, and our
recommendations include several items in this very impor
tant area.

1. Authorization to permit the State Election Board
to name Department of Motor Vehicle drivers license
examiners as special registration commissioners.

This would enable citizens to complete voter registra
tion application when they obtain or renew their driver’s
license. Such a system has worked very well in Michigan; it
has recently been recommended by Governor Robb in
Virginia and voters in Arizona adopted it by referendum in
the recent November election. This proposal is supported by
the North Carolina Division of Motor Vehicles.

2. Legislation to permit voter registration at public
high schools with school librarians as registrars.

We are all aware that registration rates among young
people are low and need to be raised. This proposal should
lead to substantial registration increases.

3. Require public libraries to permit voter registra
tion. Public library registration has been extremely success
ful in many counties in the state. The concept is strongly
supported by county election boards.

4. Legislation providing for simultaneous issuance
of absentee ballot application and absentee ballot itself.

This reform would reduce postage costs and make it
easier for qualified persons to vote absentee without
eliminating any of our existing safeguards.

5. Amendment of G.S. 163-22.1 to permit State
Elections Board to order a new election when legally

Ex-65

appropriate, after hearings have been held and findings of
fact made hy a county hoard.

This would clarify the authority of the State Board to
order a new election without unnecessarily duplicating
hearings already held hy a county hoard. The amendment
would save time, money and expedite the resolution of
election contests.

6. Authorization of constitutional amendment to
grant State Board authority to issue regulations to deal with
“out of precinct” voting problem.

Citizens and election officials alike are frustrated hy
the situation where persons move from one precinct to
another within a county hut fail to transfer their registra
tion. When registration has not been changed by election day
citizens either lose their right to vote or vote improperly in
their old precinct. A constitutional amendment is apparently ; needed here because the 30 day residency requirement for a
precinct for eligibility to vote is a constitutional requirement.

* * *
In addition to these six proposals we also suggest that

the appropriate House and Senate committees may well wish
to review the operation and administration of Article 23 and
24 or Chapter 163 regarding municipal elections and
consider whether all municipalities should contract to have
municipal elections administered hy county election hoards.

We look forward to working with you on these matters.

With best wishes,

Robert W. Spearman
Chairman, State Board of Elections

Alex K. Brock
Executive Director
State Board of Elections

RWS/ehd

cc: Members, State Board of Elections
James Bullock

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