Complaint; General Assembly of North Carolina Bills 415, 313, and 87

    a7 ) 5/

'.: i r

IN TIIE UNITED STATES I] STRICT COURT
FOR THE EASTERN DISTRICT: 

'F 
NORTH CAROTINA

RALEIGH DIVf,;ION

RALPH GINGLES, SIPPIO BURTON, FRED
BELFIELD and JOSEPI{ MOODYT on
behalf of themselves and all
others similarly situatedr

Plalntlffs,
V.

RUFUS ED!{ISTEN, in his capacity
as the At,torney General of North
Carolina; JAIIES C. GREEN, Lt.
Governor of North Carolina in his

crvrt oa*ro*

NO.

capacity as President of the North )
Carolina Senate; LISTON B. RA!{SEY
in his capacity as Speaker of the
North Carolina llouse of Represen-
t,atives; THE STATE BOARD OF
ELECTIONS OF NORTII CAROLINA; )
R. KENNETH BABB, JOHN L. STICKLEY, )
SR. T RUTH SEMASHKO' SYDNEY F' C' )
BARNWELL aNd SHIRLEY HERRING, iN
their official capacities as
menbers of the State Board of
Elections of North Carolina; and )
TEAD EURE, in his capacity as )
Secretary of the State of North )
Carolina,

Defendants.

COMPI,AINT

I. Introduction

1. This action is brought by four black cit,izens on behalf

of themselves and aII other black citizens who are eligible and

registered to vote in the State of North Carolina. They bring

this action to enforce their right to have an effective vote in-.

the election of the North Carolina General Assembly and in the

election of the North Carolina Representatives to the United

States Congress. They seek declaratory and injunctive relief to

prevent any election from being conducted pursuant to the aPPor-

tionment adopted by North Carolina in 1981 because that apportion-

ment does not comply with the one person one vote requirement and

because it dilutes the vote of black citizens. In addition they

- seek to prevent enforcement of the provisions of the North Carolina

Consitution which prohibit dividing counties in apportioning the

North Carolina General Assembly because those provisions vrere not



Precleared in accordance with 55 of the Voting Rights Act of

1965r ds amended, and because the provisions have the intent and

effect of diluting the vote of black citizens.
In 1981, the North Carolina General Assembly created the

representative districts which will be used for the next ten

years. These districts were drawn in order to dilute and with
the effect of diluting the vote of black citizens. In addition,
the total deviation between the population of the largest Senate

District and the population of the smallest Senate District is
over 22 percent; the total deviation between the population of
the largest House District and the population of the smallest

House District is over 23 percent.

Thus plaintiffs Gingles and other class members are under-

reprexented in the North Carolina House of Representatives, and

plaintiff Burton and other class members are underrepresented in
the North Carolina Senate.

The 1981 apportionment was enacted pursuant to provisions

of the Constitution of the State of North Carolina which prohibit
dividing any county in creating the legislative districts for the

North Carolina Eouse of Representatives and the North Carollna

Senate. These provisions, which lrere adopted in 1967, have never

been submitt,ed to the Department of Justice or to the United

States District Court for the District of Columbia pursuant to 55

of the voting Rights Act of 19651 ;rs amended. The effect of the

provision is to prevent the creation of single member representa-

tive districts and of representative districts with substantial

Percentages or majorities of black registeredivoters. The purpose

and effect of the provisions is to diminish the voting effectiveness
of plaintiffs and of other black voters who are members of the

class.

Final1y, in 1981, the North Carolina General Assembly enacted

a plan of districts for the United States Congress. This plan

has the purpose and effect of diluting the vote of black citizens
and avoiding the concentration of registered black voters.

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This action is brought pursuant to the Voting Rights Act of

1965r ds amended (hereafter "the Voting Rights Actr)r 42 U.S.C.

51973 et seq, and under 42 U.S.C. SS198I and 1983, pursuant to

the Fourteenth and Fifteenth Amendments to the United States

Constitution, in order to prevent defendants from holding elec-

tions fo! the North Carolina House of Representatives, the North

Carolina Senate, and the United States Congress pursuant to an

apportionment which denies blagk citizens effective rePresentation

because of their race and pursuant to an apportionment which

underrepresents them.

II. Jurisdiction
2. The Court has jurisdiction pursuant to 28 U.S.C. SS1331

and 1343 and 42 U.S.C. S1973c. This is an action arising under

the statutes and Constitution of the United States and an action

to enforce statutes and constitutional provisions which Protect

civil rights including the right to vote.

. 3. Plaintiffsr claims under 55 of the Voting Rights Act of

1965r ds amendedr and under the Fourteenth and Fifteenth Amendments

to the United States Constitution must be determined by a three

judge court pursuant to 28 U.S.C. S2284(a) and 42 U.S.C. SI973c.

4. Plaintiffs seek declaratory and other appropriate

relief pursuant to the Declaratory Judgment Act, 28 U.S.C. SS2201

and 2202.

III. Parties

5. Plaintiff Ra1ph Gingles (hereafter 'Gingles") is an

adult black citizen of the United States who resides in Gaston

County, North CaroJ.ina. Gingles is properly registered to vote

in elections of the North Carolina House of Representatives and

Senate.

6, Plaintiff Sippio Burton (hereafter 'Burtonn) is an adult

black citizen of the United States who resides in Cumberland

County, North Carolina. Burton is properly registered to vote in

elections of the North Carolina llouse of Representatives and

Senate.

7. Plaintiff Fred Belfield (hereafter nBelfieldn) is an

adult black citizen of the United States who resides in Nash

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County, North Carolina. Belfield is properly registered to vote

in elections of the North Carolina House of Represent,atives, the

North Carolina Senate, and the United States Congress.

8. Plaintiff Joseph ltloody (hereaf ter nMoodyn ) is an adult

black citizen of the United States who resides in Halifax County,

North Carolina. Moody is properly registered to vote in elections
of the North Carolina House of Representatives, the North Carolina

Senate, and the United States Congress.

9. Defendant Rufus Edmisten is an adult resident of the

State of North Carolina. He is sued in his official capacity as

Attorney General of the State of North Carolina on behalf of the

State of North Carolina. In his capacity as Attorney General, it,
is his duty to represent the State in all civil actions in which

the State is int,erested.

10. Oefenaant James C. Green is an adult resident of North

Carolina, He is sued in his official capacity as Lieutenant

Governor of North Carolina and as President of the North Carolina

Senate.

11. Defendant Liston B. Ramsey is an adult resident of

North Carolina. He is sued in his official capacity as Speaker

of the North Carolina House of Representatives.

L2. Defendant Thad Eure is an adult resident of North

Carolina. He is sued in his official capacity as Secretary of

State of North Carolina. In. that capacity it is his duty to
certify the results of all North Carolina elections to the United

States Congress and aI1 elections to the North Carolina Senate
i

and House of Repreientat,ives from multi-county districts.
. 13. Defendant State Board of Elections of North Carolina

(hereafter nthe Board of Elections') is responsible for supervis-

ing and conducting primary and general electlons in the State of

North Carolina. It has the authority to control the conduct of
primaries and general elections. It is also responsible for
comPuting the results of multi-county elections.

14. Defendant R. Kenneth Babb is a resident of North

Carolina and a member of the Board of Elections and is its
Chairman.

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15. Defendant John L. Stickley, Sr.7 Ruth Semashko, Sydney

F. C. Barnwell and Shirley Herring are residents of North Carolina

and members of the Board of Elections.

15. As members of the State Board of Elections, defendant,s

are authorized to exercise the powers and duties of the State

Board of Electibns.

IV. Class Action

L7. Plaintiffs bring this action as representatives of the

class of all black residents of the State of North Carolina who

are eligible to and registered to vote.

- 18. The class is so numerous that joinder of all members is
impracticable.

19. The question of the legality and constitutionality of
provisions of the North Carolina Constitution and the apportion-

ment of the North Carolina General Assembly and Congressional

Districts which are at issue raise questions of law and fact
conmon to the class

20. The claims of the representative parties are typical of

the claims of the other class members.

2L. The represent,ative parties have a personal stake in

this controversy and have retained competent and experienced

counsel to represent them. They will fairly and adequately

protect the int,erest of the class.

22. The prosecution of separate actions by individual
members of the class would create a risk oi inconsistent or

varying adjudications which would establish incompatible stan-

dards of conduct for defendants. The State of North Carolina can

have only one plan to apportion the representative districts of

its legislature and congresslonal districts. Inconsistent adjudi-

cation of the legality of the current apportionment or of the

requirements of a future apportionment would establish incom-

patible standards of conduct for defendants.

23. Since North Carolina conducts elections in accordance

with only one apportionment and in accordance with the North

Carolina Constitution, defendants have acted and refused to act

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o

on grounds generally applicabLe to the c1ass, thereby making

appropriate final injunctive relief and corresponding declaratory

relief with respect to the class as a whole.

V. COUNT ONE: NORTH CAROLINA CONSTITUTIONAL PROVISIONS
6ME'FN-ruc AppoRTToNMENT oF TrrE NoRTH cARoLTNA GENERAL
ASSE!4BLY.

24. The North Carolina General Assembly consists of the

Senate and the House of Representatives.

25. In L967, North Carolina amended its constitution to
change the manner of apportionment of the General Assembly.

26. Article II, S4(3), rras adopted and provides that no

c.gunty shall be divided in the formation of a Senate district.
27. The 1969 revision of the North Carolina Constitution

retained this provision but renumbered it to become Article II,
s3(3).

28. Prior to L967 the North Carolina permitted the General

Assembly to divide a county in forrning of a Senate district if
that county was entitled to two or more Senators; since 1967 the

North Carolina Constitution has prohibited the General Assembly

from dividing a county in forming a Senate district.
29. In 1967r the North Carolina Constitution was amended by

adopting Article II 56(3) which provides that no county shall be

divided in the formation of a representative district.
30. The 1959 revision of the North Carolina Constitution

retained this provision but renumbered it to become Article II,

i

3I.' Prior to L967, the North Carolina Cdnstitution provided

that most representative districts were to be single member

d istricts .

32. Forty of North Carolinars counties are subject to 55 of

the Voting Rights Act, 42 U.S.C. SI973c.

33. Elections in each of these forty counties were affected

by the L957 amendments to the North Carolina Constitution.
34. The named plaintiffs reside in four of the counties

which are covered by 55 of the Voting Rights Act of 1965r ds

amended.

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35. North Carolina did not submit the 1967 amendments to
the North Carolina Constitution to the Attorney General of the

United States for approval pursuant to 42 U.S.C. g1973c, nor did
North Carolina obtain a declaratory judgment from the United

States District Court for the District of Columbia that the

constitutional Amendments do not have the purpose and will not

have the effect of denying or abridging the right to vote on

account of race or color.
36. The purpose and effect of the L967 amendments to the

North carolina constitutionr 6s described in paragraphs 25 and

2: above, is to dilute the voting strength of black citizens and

to deny them the effective utilization of the right to vote on

account of their race.

37. fn 1981, North Carolina enacted a reapportionment of
its General Assembly.

38. According to the United States census for 1980, the

population of Gaston Countyr Nqrth Carolina, in which plaintiff
Gingles resides, is 162t568.

39. If the North Carolina Constitution did not forbid divid-
ing counties in creating representative districts, Gaston County

could be divided into three representative districts.
40. According to the United States census for 1980, the

population of Cumberland County, North Carolina, in which plaintiff
Burton resides, is- 247 1150.

41. If the North Carolina Constitution did not prohibit divid-
ing senatorial districts, Cumberland County could be divided into
at least two senatorial districts.

42. fn each instance, dividing the county would concentrate

the vote of black citizens and enhance the effectiveness of the

vote of bl.ack citizens.
43. The 1981 apportiorunent of the General Assembly obeys

the North Carolina Constitutional prohibition against dividing
counties and, therefore, has the effect of diluting the vote of
black cit,izens.

44. The Board of Elections will supervise and conduct elec-
tions for the North Carolina General Assembly in even numbered



years from 1982-1990 in accordance with an

pursuant to Article II, SS3(3) and 5(3) of

Constitution unless the Court orders them

apportionment adopted

the North Carolina

not to do so.

A. First Claim for Relief
45. Plaintiffsr first claim for relief is brought pursuant

to 55 of Voting Rights Act of 1965r eis amended, 42 U.S.C. S1973c.

46. Defendants continue to enact apportionment plans and to

conduct and supervise elections for the North Carolina House of

Representatives and the North Carolina Senate in accordance with

Article II, SS3(3) and 5(3) of the North Carolina Constitution.

itris practice violates 55 of the Voting Rights Act since North

Carolina did not submit these provisions either to the Attorney

General of the United States or to the United States District
Court for the District of Columbia for approval in accordance

with 42 u.s.c. 1973c.

B. Second Claim for Relief

47. Plaintiffsr second claim for relief is brought pursuant

to 52 of the Voting Rights Act of 1965 as amended, 42 U.S.C. SI973.

48. The provisions of the North Carolina Constitution which

prohibit dividing counties in the establishment of representative

and senatorial districts vrere adopted with the purpose of prevent-

ing a substantial number or majority of black voters from compris-

ing a representative or senatorial district and with the purpose

of preventing black citizens from effectively exercising their
right to vote on account of race or color.l i

49. The effect of these provisions of the North Carolina

Constitution is to dilute the vote of black citizens and, thus,

to deny and abridge their right to vote on account of race or

color.

C. Thlrd Claim for Rellef

50. Plaintiffsr third claim is brought pursuant to 42

U.S.C. 51983 to enforce the equal protection clause of the Four-

teenth Amendment and the Fifteenth Amendment to the United States

Constitution and pursuant to 42 U.S.C. 51981.

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51. The provisions of the North Carolina Constitution

which prohibit dividing counties in the establishnent of represen-

tative and senatorial districts were adopted with the purpose of

preventing a substantial number or a majority of black voters

from comprising a representative or senatorial district and with

the purpose of preventing black citizens from effectively exercis-

ing their rlght to vote on account of race or color.

52. The effect of these provisions of the North Carolina

Constitution is to dilut,e the vote of black citizens and, thus,

t,o deny and abridge their right to vote on account of race and

co_Ior.

IV. COUNT f'l{O : }TALAPPORTIONMENT OF THE NORTH CAROLINA
ffiE-nal aSSEMBLY

53. In 1981, North Carolina enacted a reapportionment, of

the North Carolina General Assenbly.

54. A true and accurate copy of Chapter 800 of the Session

Laws of 1981 which est,ablishes representative districts for the

North Carolina llouse of Represent,atives is attached as Exhibit A

to this Complaint.

55. A true and accurate copy of Chapter 821 of th Session

Laws of 1981 which establishes senatorial distrlcts and apportions

the seats of the North Carolina Senate is attached as Exhibit B

to this Complaint.

56. The 1981 apportionment of the General Assenbly does not
'I

have Representative or Senate districts with a, reasonably equal

number of citizens per Representative or Senator.

57. The average population per member for the North

Carolina House of nlpresentatives is 48r954.

58. The plan which the North Carolina General Assembly

enacted has districts which range from a population of 55 1286 in
Ila1ifax County to a population of 43,724 per member in the three

member district composed of B1aden, Columbus and Sampson Counties.

59. This deviation of population from the average popula-

tion per member results in a overall range of deviation of 23.6

percent.

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50. Plaintiff Gingles, plaintiff Dloody, and the other

class members are underrepresented in the North Carolina House of
Representatives .

61. The average population per member of the North Carolina

Senate is tL7,48g.

62. Under the plan adopted by North Carolina, Senate

Districts range from a population of 132.374 per senator in the

Senate district composed of Harnett, Lee and Wake Counties to
105,718 in the Senate district which consists of Guilford County.

63. This deviation of population from the average popula-

tlon per Senator results in a overall range of deviation of 22.'l

percent.

64. Plaintiff Burton and the other class members are

underrepresented in the North Carolina Senate.

65. At the time when the- apportionment of the North Carolina

General Asembly was adopted, the members of the General Assenbly

knew the extent of the deviation of population sizes from the

average population Per district, and they enacted the apportionment

disregarding this deviation.
A. Fourth C1aim for Relief

55. Plaintiffsr fourth claim is brought pursuant Eo 42

U.S.C. 51983 to enforce the equal protection clause of the

Fourteenth Amendment to the United States Constitution.
67. The apportionment of the North Carolina House of

Representatives and the North Carolina Senate as described in
paragraphs 53 through 55 above results in plaintiffs' being

underrepresented, does not comply with the "one person--one vote'
requirement for legislative apportionment, and denies plaintiffs
their right to equal protection under the Fourteenth Amendment to
the United States Constitution.

VII. COUNT THREE: DILUTION OF BLACK VOTE IN NORTH
ffiOtriiiE-En ERAL As s Err{BLy

58. The apportionment of the North Carolina General

Assembly enacted in Chapters 800 and 821 of the Session Laws of

1981 has the purpose and effect of diminlshing the concentration

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of black voters and decreasing the effectiveness of the vote of

black citizens.
A. Fifth Claim for Relief

69. Plaintiffsr fifth clairn is brought pursuant to 52 and

55 of the Voting Rights Act of 19651 6s amended, 42 U.S.C. SS1973

and 1973c.

70. The intent and effect of the apportionment of the North

Carolina General Assembly which North Carolina adopted in 1981 is
to dilute the vote of black citizens and to deny plaintiffs their
right to use their vote effectively.

- B. Sixth Clain for Relief

71. Plaintiffsr sixth claim is brought pursuant Eo 42

U.S.C. 51983 to enforce the equal protection clause of the

Fourteenth Arnendment and .the Fifteenth Amendment to the United

States Constitution and pursuant to 42 V.S.C. 51981.

72. The intent and effect of the apportionment of the

North Carolina General Assembly which North Carolina adopted in

1981 is to dilute the vote of black citizens and to deny black

citizens the right to use their vote effectively.
VIII. COUNT FOUR: APPORTIONIT{ENT OF UNITED STATES

coffiitAL DrsrRrcrs

73. In 198I North Carolina enacted a reapportionment of its
representative districts for the United States Congress.

74. A true ald accurate copy of Chapter 894 of the North

Carolina Session Laws of 1981, which establishes representative

districts for the United States Congress, is attached to this
. Complaint as Exhibit C.

75. Plaintiffs Belfield and Moody are eligible to vote and

are registerei to vole in the Second Congressional District.
'16. North Carolina excluded Durham County from the Second

Congressional District for the purpose of and wlth the effect of
preventing the black citizens of the Second Congressional

District from effectively exercising their right to vote.

A. Seventh C1aim for Re1ief

77 . Plaintiffs I seventh claim for relief is brought pursuant

to 52 and 55 of the Voting Rights Act of 1965r ds amended, 42

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U.S.C. S51973 and 1973c.

78. North Carolinars apportionment of its representative

districts for the United States Congress has the purpose and

effect of diluting the vote of black citizens and of denying

black citizens the right to use their vote effectively.
B. Eight Claim for Relief

79. Plaintiffsr clain for relief is brought pursuant to 42

U.S.C. 51983 to enforce the equal protection clause of the Four-

teenth Amendment and the Fifteenth Amendment to the United States

Constitution and pursuant to 42 U.S.C. 51981.

. North Carolinats apport,ionment of its representat,ive

districts for the United States Congress has the purpose and

effect of diluting th." vote of black citizens and of denying

black citizens the right. to use their vote effectively.
V. Equitable Relief

81. In 1971 the North Carolina General Assembly was appor-

tioned in accordance with the provisions of the North Carolina

Constitution.

82. In Lg72t !974, L976, 1978 and 1980, defendants con-

ducted elections pursuant to the L972 apportionment plan.

83. Unless the Court orders defendants otherwise, in L982

defendants will supervise and conduct elections for the North

Carolina Senate, the North Carolina House of Representatives, and

the United States Congress pursuant to Chapters 800, 82L and 894

of the North Carolina Session of 198I.

84. Plaintiffs have no remedy at lawiwhich is an,adequate

redress for being $eprived of their right to vote and for being

represented by a legislature that is illegaIly and unconstitu-

tional.ly constituted.
' VI. PrayeE for Relief

WHEREFORE plaintiffs pray that the Court:

1. Convene a three judge court in accordance with the

provisions of 28 U.S.C. 52284i

2. Certify this action to be a class action;

3. Declare that Article II, S3(3) and S5(3) of the North

Carolina Constitution are in violation of 55 of the Voting Rights

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Act of 1965r ds amended, and enjoin defendants from enacting any

legislation and from conducting, supervising, participating in,
or certifying the results of any election pursuant to an apportion-

ment which was enacted in accordance with these constitutional
provisions until and unless these constitutional provisions have

been submitted and approved in accordance with 42 U.S.C. S1973c;

4. Declare Article II, 53(3) and 55(3) of the Constitution

of North Carolina to be in violation of 52 of the Voting Rights

Act of 1965r ds amended, and the Fourteenth and Fifteenth Amend-

ments of the United States Constitution and enjoin defendants

from enacting any apportionment of the North Carolina General

Assenbly in accordance with these provisions and from conducting,

participating in, supervising or certifying the results of any

election for the North Carolina Senate or the North Carolina

House of Representatives pursuant to any apportionment enacted in

accordance with. these constitutional provisions;

5. Declare that apportionment of the North Carolina Senate

and North Carolina House of Representatives as enacted in Chapters

800 and 821 of the North Carolina Session Laws of 1981 violates

the equal protection clause of the Fourteenth Anendment to the

United States Constitution because the apportionment does not

have representation districts which are equal in size and enjoin

defendants from participating in, supervising, conducting, or

certifying the results of any election pursuant to this apportion-

ment and from enacting any apportionment in the future which has

representation districts which are not "qrit in size;

6. Declare that the apportionment of the North Carolina

€enate and the North Carolina llouse of Representatives as enacted

in Chapters 800 and 821 of the North Carolina Session Laws of

1981 dilutes the vote of black citizens and denies ptaintiffs and

other class members the right to use their vote effectively
because of their race in violation of g2 and 55 of the Voting

Rights Act of 1965r trs amended, in violation of the Fourteenth

and Fifteenth Amendments to the United States Constitution, and

in violat,ion of 42 V.S.C. 51981 and enjoin defendants from

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participating in, supervising, conducting or certifying the

results of any election pursuant to this apportionment and from

enacting any aPPortionment in the future which has the purpose or
effect of diluting the vote of black citizens because of their
race i

7. Decrare that the apportionment of the representative
districts for the United States Congress as enacted in Chapter

894 of the Session Laws of 1981 denies plaintiffs and other class
members who reside in the Second Congressional District, their
right to use their vote effectively in violation of 52 and 55 of
Vgting Rights Act of 1965r ES amended, in violation of the

Eourteenth and Fifteenth Amendments to the united states
constitution, and in violation of 42 u.s.c. 1981, and enjoin
defendants from participating in, supervising, conducting, or

certifying the results of any erection pursuant to this appor-

tionment and from enacting a plan of apportionment of united
States Congressional Districts in the future which has the purpose

or effect of diluting the vote of black citizens because of their
race i

. Award the costs of this action, including reasonable

attorneyst fees, to plaintiffs; and

9. Grant praintiffs such other and further rerief as may

be just and appropriat,e.

rhis lQ day of 4., 0 , , 1eet.

ambers, Ferguson, Watt, Wallas,
Adkins & Fuller, P.A.

951 South Independence Boulevard
Charlotte, North Carolina 28202
704/375-8461

JACK GREENBERG
JAITES M. NABRIT, III
NAPOLEON B. WILLTAMS, iIR.
10 Columbus Circle
New York, New York 10019
2L2/5e5-8397

Attorneys for Plaintiffs

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\-,

GENERAL ASSEMBLY OF NORTH; CAR'0LINA

SESSION 1981

RATIFIED BILL

CEAPTEB 8OO

EOrrsB Brtt 415

AN ACT TO APPORIIOT THE DISTBICTS OF TEB NORTE

R EPRESE ITATIVES.

The Geueral Asseobly of Xorth Carolina enacts:

CABOLIIIA HOUSE: 0P

. Section 1. G.S. 120-2 is reurltten to read:
rrl 120-2. House apportionnent specifie{.--For the purpoSe ot

nonioatiug aatl electiug lenbers of the f,orth Carolila Bouse of
!

Represeotatives in 1982 autl every tro years t],ereafter, the State
of North Caroliua shalL be divided iato forty-four ctistricts .as

follors:
District 1 shall cousist of

Pasguotank, PerquiDaDs, fyrrell,
shall elect tro Bepreseatatives.

'l

District 2 shall consist of
shalL elect one Bepresentative.

District 3 shall cousist of cravea, .rones, Lenoir, aad panlico

Counties, autl shall elect three Represeatatives.
District { shall consist of carteret aarl onslor cou[ties, and

sball elect three Bepresentatives.

District 5 shalI consist of Bertie, Gates, .Hertford, iartia,
and llortbanpton CouotieS, and sball elect tro nepreseotatj.ves.

District 5 shall coasist of Ealifar couutyriaad shall el6ct one
,,Represeutative.

It--
Cardlea, Choran, Currituck, Dare,

aud lashiagtou. Couuties, aud

Beaufort and Eyde Couaties, and

EIGIIBIT A--5 pages



. 1. I J..- i

District 7 shall ' consiSt of Eclgecoobe, I lIash, and flilsou

counties, and shal1. elect four BePresentatives'

District 8 slla]I consist of creene aDd Pitt counties, and shall \-/

District 9 shaII consist of Hayne Couuty, anit shall elect-tro

RepEeseDtatiYes.

District 1o shall consist'of.'.8obesoD countyr, ancl shaII elect

District 11 shall consj.st of Brunsrick, Duplin, ancl Peutler

Counties, and shall elect tuo BePresentatives'

District 12 shall consist of Ner Eanover County, aad shaLl

, Di-strict 13 .shall coDsist'of Casrelli,Granville, Person, VaBce,

anti larren CountiesT and shall elect three "Bepreseutatives' ''.'
i
District 1q shall coosist of "Franklin'antI .Iohnstou Counties,

auci shall elect tuo RePEeseutatives.
, t-)

District 15 shall consist of rake county, atrd shall electr'sir

Represeut atives.

District 16 shall coasist of Durhan CouDtIr, aucl shall elect

three Bepreseatatives-

District 17 shall cousist of Chathao antl Orange Counties, aud

.l

shali elect tso BePEeseDtatlves.

District 18 shall consist of Ha'rnett aocl Lee Couuties, antl

shall elect tro RePresentatj.ves. ,

District 19 shall cousist' of Blacten, Colunbus, and Saupsou

couoties, and shall -elect tbree BePEeseutatives.

\-/

Eouse BilI 415

I



l

l

I

I

Ilistrict 20 shall consist of CuubeElaDd CouDty, and shall elect
fiveRepresentatiyes. ' ':

'Y District 21 shall consist of Eoke'aad Scotlancl Couutiesr aDd

shall elect one Represeltative. - :

;iDistrict 22 shall'consist of ALanance aacl Rockinghan Couutles, ; i

I

Iancl sirall elect four Represeutatiyes.

District 23 shal-l coosist of Guilfortl County, aDd sbalf elect

seven Representatiyes.. i

District 24 shall coasist of: Randolph County, and shaLl elect,

tro Representatives. : --

District 25 shall cousist of lloore County, aud shall elect oDe.

Representative -ri i:

District 26 shall cousist of Ansou aadl f,ontgonery Couutiesl ,6ad ' ' : .

shall elect one Represeutatj.ve. , : 
i

:

District 27 sira1l cousist oi Ricbuoud Countyr'aDdl. shall elect
\-/

oDe Representative. ' .'

District 28 shall coasist of Alleghany, Ashe, Stokes, Surry,

and tlatauga Couoties, aaal' shall elect three Bepresentatiyes.. ','
;

iDistrict 29 shall consist of lorsyth County, ancl shall elect ' 
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,.District30shaILconsistofDavidsonan<lDavieCouutiesranc[

shall elect tirree Representatives.

District 31 shall coasist of Royatr Couaty, and shall elect tuo

Represeatatives. :

. District 32 shall gonsist of Staaly County, and shall elect oae

: BepreseDtative I

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House BiIl 415



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- Dis:trict 33 shall bosist of Cabarrus -and Unio'l Couuties, aucl

shall elect thtee Bepreseotatiyes. ' ' i

Drstrict 34 shall cousist of Calclrelle llilkesr aud Yadlcin ..J
couoties, and shall elect three Bepresentatives.

District 35 shall coosist of ,A.leraa<ler ancl Iretlell Couuties ,

Drstrict 36 sball consist 'of. 'tteclsleaburg Couuty, and shaIL

elect nioe Bepreseutatives.

District 37 shall cousist of Catarba Cbuuty, autl shall elect.

tro Bepreseutatives.

District 38 sha].l cousist of 'Gastoo aocl tiacoln Counties, aocl

sball elect four Represe[tatives.. -,..'

District 39 'sball consist of AYeEy, Burke, and [itchell
:

Counties, and shall elect tuo BePreseDtatives-

District 40 sbatl cousist of Cleveland, Polk, and Rutberford -

Counties, andl shall elect three Bepreseutatives. !
District lt1 shall coosist of ltcDorell'auct lancey Couutiesr trDd l

shal-L elect one BepresentatiYe.

District 42 shall consist" of Bunconbe, Henclerson, aad

Transylvaaia Counties, autl shatt elect five Representatives.

District 43 sha1l consist of Eayuood, Jacksoo, Eaclison, and

Srain couuties, an<l shall elect tro. Bepieseutatives-

' ,i"a.i"a 44 shall consist of Cherokie, CIay, Grahar, and ltacon

Counti.es, antl shall elect'one':BepreseDtative.n

House Bill 415



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lpoD ' ratlficat.loa.;,

rn the' General tsgelbll' Eead three tiles aud:ratified,

this the 3rd day of iluly, 1981.

JAMES C. GREEN

ilaleg C. Greea

Presldlent of, the seuate

,

USTOTI B. RAMSEY

LLstos B. BauseY

Speaker of, tbe Bouse of Bepreseatatives

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House BiIl lt15 C.

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GENERAL ASSEMBLY OF NORTH CAROLINA

SESSION 1981

RATIFIED BILL

CEIPTEB 821

,SBIIATB. BII.L 313

AN ACT TO ESTTBLISB SEXIIOEITL DISTBICTS AXD TO APPOSIIOtr SEAIS

folloriag iuserted ia lieu thereof:
tt I 120-1- Seaators. --FoE the purpose of nolinating ancl
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.r;; Senate iu lgaz anrt eveEy tro yearselectiog leub,

thereafter, senatorial districts are established anil seats ia the

Seuate are apportioaetl auotrg those tlistricts as follors: ,

District 1 shall cousist of Beaufort, Bertie, Canrlen, Chorau,

Currituck, Dare, cates, .Eertford, Eydle, Xorthalptoa, Pasquotauk,

Perquinaus, Tyrrell, aud lashingtoa Couaties antl shall elect tro

III THE SEf,ATE AIOIIG DISTBICTS.

The General Asseobly of llorth Carolioa euacts:

Section 1. G.S. 120-1 is hereby deleted

SeDators

Distrj.ct 2 shall consist of Carteret,

Counties aud sha]']. elect one Seuator.

District 3 shall cousist of Onsl.or Couuty

Senator.

District tt sball coasLst of trer Eanover and

shalI elect one Seuator.

District 5 shall consist of Dupllu, ilones,

Dj.strict 5 shalt coasist of Edtgeconbe and

sball elect oue Seuator.

aad the

Craven, and, Paalico

audl 'shaIl elect oae

Pentler Couuties ancl

Lenoir Couaties

ar Couaties aad

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EICIIBIT B--4 pages



. ''District '7 shall Consist of Ea,rtin ald Pitt Couaties aad shall
etect one Senator. 

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District 8 shall coosi,st o.f, Fraaltli,!, Hash, Yauce, ilarren, and

Iilson Couati.es antl shall elece.,tro ,seuators.

District 9 shall coasist of Gree[e aad rayne Couaties aDd shalt

District 10 shal-l coosiat of, JoLsstou aual Sanpson Counties ancl

shall elect one Seoator.

District 11 shaLl coasist of' Culberlancl County aotl shall elect

tro S€oators.

District 12 shalJ- coasl,st'of' Bladeo, Bruusrick, anct Coluabus

Courrties aad shall elect one SeoatoE.

. District 13 sha].l . consi,st of Eoke and Bobesor Couaties.aud
s

shall elect one SeDator.

District 14 shal'l. coDaist of .Durhal, Graaville, aad Persou

Counties aud shall elect tro.SenatoEs.

District 15 shall coosist of Earnett, Lee ,ancl ttake Couuties arl
shall elect three Senatorg. \ i .

. District 16 shall coasist of .lilJ.eghaly, Asbe, Surry aad flatauga

Couuties aad sball elect one SeaatoE.

, District 17 sball consist..of BoclLaghar andl Stokes Counties aadl

shall elect oue Senator.

orange, .aadl. District 18 shalJ. . consi.gt of CLat'han,, tlooEe,

Raarlolph Counties aacl sball elect tro SenatoEs.

District 19 sh-all coaaist of,, 'A[soa, !o[tgor€E:i, Eicblolcl,

Scotlaucl, Stauly, aad thi.ou @uaties aad i shal,l elect tuo

Seoators.

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Seuate2 BiLL 313



' District 20 shall couiist of alaoance aacl casrell counti.es anrl

shall elect one SeDatoE.

'\./ District 21 shall cousi.st 'of Forsyth County aad shalL elect tro
' Setrators. . '

.. District 22 shall coasist of Guilfor<l Couuty anct shall E1ect
three SeDatoEs

District 23 shal1 coosist of Davidsoo, Davie, aud Roran

Couuties aucl sirall elect tro Senators.
District 2tl shall consist of cabarrus aad f,eckleoburg Couaties

and shall elect four Sena_tors

District 25 shall coasist of llexander, Catarba, rredell, aucl

radkin counties and sharl elect tyo seaators.
i

Drstrict 26 shall consist of Avery, Burke, calduell, llitchell,
and Hirkes couuties aacl shall elect tuo seaators.

District 27 shall coasist of Cleve1audl, Gaston, Liacoln, an<l
\-,

Rutherford counties and sharl elect three seDators.
District 28 shall cousist of Buncoube, laclison, HcDoreLl, aad

raacey counties ancl shal,r erect tro senators.
District 29 shaIL cousist of Cherokee, CIay, Grahau, Bayuoocl,

HeodersoD, Jacksou, lacoD, Polk, Suaiu, aad fransylvania Counties
. ancl shall elect tro Seoators.o

Senate 8i11 313



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. Is thc Gelonl le.r^bI,, rcrd,throc ltilcs aatl ratificit;
.l

this tbe 3fdl nfy Of JUlf llEtf. " ,' '; " 1 :'" ";;:'ii ' "''i :: l:';' n:'1 'J
'..1.,.i}-t*....l(ll.1i,i,r.,..df.':,j..''..'

:

JAT'ES.C. GREEN

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. a .-,Ji,f C- C'iieU'j :. . ' .. :'-.:'1r 3..rt;' ..
.. I

'r' Prri.i.ileBt 61 tbolseaate" ': i -:1'

: :i. ;';.if{:.(.:r'"r,:ii...:;, i , i.r..i'.'i.;.i ..;:,r.'il .t4F!:l-'.

tl!tm-' Bi' .Batsey

Spriinr:of the'' Ebuge of BcpEeaeltatives

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isearte 8111 313

/r



GENERAL ASSEMBLY OF NORTH CABOLINA

SESSION 1981

RATIFIED BILL

cElPrBR 894 : "

SEIIATE BT1L 87 I

AII ACT TO DIYIDE XORTE CTEOITTTT IXTO ELEYETI CO}TGBESSIOITL

DISlRICTS.

The Geoeral. tsseobly of llorth Caroliaa euacts: ::

Section t. G.s. 163-2011 is reurlttea to reacl. I '

ng 163-201. 
.!ouqressioua]. dlstricts specLfied.--(a) For the

purp.ose of norinati.ng a[<t electing lelbers of tbe Bouse . of

Bepresentatives of the Congress of the Uuitecl States in 1982 and

eYery tuo yeaEs thereafter, tbe'State of Xorth Caroliua shall be

di.vided iato 11 districts as follous:
FIIiSI DISIRICI: Beaufort, Bertie, Canden, Carteret, Choraa,

de, Leaoir,Craven, Currituck, Dare, Gates, GreeDe, Eertford, EI

Uartio, Northanpton, Panlico, Pasquotaak, Perqui.rans, Pitt,
TyrreII, aad lashiagtou 

.Counties.
SECOND DISIRICf: Alalatce, Casrell, 'Chathan, Erlgeconbe,

Erankliu, Grinville, Ealifaz, f,ash, PeEsoD, Yancer. Iarrelr. aadl

llilson Counties.

THIRD DISIEIC!: Bladen, Duplia, Earuett, ilohnston, tfoles, Lee,

Oaslor, Pesaler, Sc[psonr atd lEfD€ Counties.

fOUBIU DISIBICI: Durhal', Oraage, aod fake Courrties.

FIFTH DISIRICI: llera[der, fllegbaay, Ashe, Forsyth,

Eockiaghar, Stokes, Surry., antl litrkes Couaties.

SIXTH DISIBICf: Drvidsoa, eullford, aud Baadolph CountlesS aud

ooly the folloriag touuships of loore Couaty: TorasLip 1

EXIIIBIT C--3 pages



(ti,rtirage) r- i.orashipr 3 (SLeffielcls) , T.o.rnship q (Bitters) ,
Tornship, 5 (Deep Biver) , 'aacr roraship 5 (Greenrooct) .

. :.':.' ..sEvBlt'JH DISIgICI:. Bruas*ick, Coluobus, Cuuberland, Ifer.

Hanover, and Robesou Counties-. .. t ', _,'_

' ETGHTH. DrstRrcr:. lusotrr, ca:bar.rus, Da.yie, tsoker. uontgooery,
Richnoud, Roran, Scot.raacl, stanlyr, 0aioa, alcl ra6kiu couaties;
an<l alr toraships of loore couutl ercept.:. Eoraship 1 (carthage) ,

ip 5t (Deep

Liver), Toraship 6 (cEeearoodr.

ilrNtH: DrstRrcr: rreclell, LLqcolnr..anrl. leclcrenbuEg couDties.
fEN1fl. ofstaicf : tvealfr. Burker.-Caldrellr. Catalba, Clevelau<l,

Gastonr. and Hatauga Coulties..
BLEvEf,TH DrsrBrcr:. . goo;oiber, cherokee, clay,, Grahao, Hayroocl,

\
Hendersoo, Jacksoa, !.acour, f,adis9Dr.,. f,cDorellr, litchell, polkr.

Rutherforil, sraiu, transylvaniar, aae. raocey couuties.
(b) T.he DaDe aucl bounclari". or, tornships specified iq, this

sectios. are as they rere reg.ally defiaed auil in. effect. as of
January lr.1980r. and.recoguize.il in, tbe. 19g0,u.,s.. ceDsus.rr 

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Senate Bill 87

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Sec. 2. this act is effective upou ratifi.cation.
rn tbe Geqeral asselbly read thrlee tires aacl ratified,

tbis the 9th day of iluly, 1981.

'1

JAMES C. GREEN

Jales c. GEeeD

Presirteut of the Seuate

LISTON B. RAMSEY

Listou B. Balsey

Speakei of the Eouse'of Bepreseutatives

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Senate BIII 87