Jurisdictional statement - About Redistricting - Loyola Law School

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71a and you mentioned the name Patrick Dennis. Who is he? A. Patrick Dennis is our chief counsel of the judiciary committee. Q. The judiciary committee? A. Correct. Q. And you indicated he would communicate some information— A. Any bill we put up, any amendment that we put up, it did have the black voting-age population on it and Patrick would highlight or just point, just giving information, purely—he was not making a decision, he was just purely giving information to the chairman. The chairman would then move to table. He had three votes, and it didn't matter what the amendment was, if that black voting-age population went down a percentage point he would— Q. And did you ever talk to Mr. Clemmons about this? A. At length. Q. And his reasoning for doing that— A. I talked to Mr. Clemmons. I even talked to— attempted to talk to House counsel about this, and he did not have a * * * * [24] hired counsel for a legal opinion and take a break was so that we could actually get a why. But that never was given. The only issue that Alan Clemmons ever had in his mind, as you listen to the tape, he did not discuss public testimony, he did not discuss communities of interest, the only thing he
72a talked about was race. That’s the only thing he ever talked about. That was his only basis for tabling anything that came up in our subcommittee. Q. How many people were on the subcommittee? A. Five. Q. And you indicate two African Americans? A. Correct. Karl Allen was there along— Q. Okay. And the other members of this committee, when he made a motion to table, is there any discussion? A. I never had any discussion with them. It was rare. Most of my discussion, which if you listen to all six hours or eight hours of tape, which got somewhat heated at times, was with the chairman. Q. And when you indicated on the record, you said if you balance that with what we heard this morning about the simple fact of people wanted people to keep Barnwell County whole, this line that you can’t take black people’s percentages down is not actually what the law says, was there any response, either on the record or off the record, about keeping Barnwell County whole? [25] A. There was public testimony about keeping— Q. I’m talking about from Mr. Clemmons when you said keep it whole. A. No. And even—there was not even a comment from counsel about the principles. Q. Okay. Did you make Amendment number 13? A. Yes. Q. Okay. Can we see Amendment number 13?
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No. 11-___ IN THE Supreme Court of
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TABLE OF CONTENTS QUESTIONS PRESENT
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v TABLE OF CONTENTS—Continued Pag
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vii TABLE OF AUTHORITIES CASES Page
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ix TABLE OF AUTHORITIES—Continued
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IN THE Supreme Court of the United
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3 was twofold: (1) to minimize the
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5 leaders explained these districts
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7 55, governed South Carolina’s H
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9 that had a lower BVAP percentage
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11 position: as a matter of policy,
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13 (R-Horry) shared this cold blood
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15 testimony did not show that “r
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17 lower court failed to recognize
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19 danger was too great that partis
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21 a generalized assertion of past
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23 necessary to enforce the VRA con
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25 “predominant factor” decisio
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27 motives, some legitimate and som
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29 A. Hays’ standing doctrine is
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31 B. Plaintiffs have standing to i
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33 * * * In Georgia v. Ashcroft, th
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35 sider evidence on a statewide ba
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APPENDIX
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2a ———— Judge Duffy wrote t
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4a 1965, 42 U.S.C. § 1973, 42 U.S.
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6a U.S. at 905. Race may be a facto
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8a composition of their district wo
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10a communities of interests, and i
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12a Even granting Dr. McDonald the
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14a ground other than race, see Sha
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16a tricting process. All three of
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18a the Subcommittee, as a whole. O
Page 67 and 68: 20a ment scheme has on the opportun
Page 69 and 70: 22a therefore cannot state a § 2 c
Page 71 and 72: 24a (quoting City of Mobile v. Bold
Page 73 and 74: 26a General Assembly acted with suc
Page 75 and 76: 28a elections. Id. Not a single whi
Page 77 and 78: 30a APPENDIX B THE UNITED STATES DI
Page 79 and 80: 32a APPENDIX C THE UNITED STATES DI
Page 81 and 82: 34a APPENDIX D THE UNITED STATES DI
Page 83 and 84: 36a seriously doubted, but neither
Page 85 and 86: 38a 10. When the Federal Court drew
Page 87 and 88: 40a 16. When the Federal Court drew
Page 89 and 90: 42a House District as adopted durin
Page 91 and 92: 44a center located in the heart of
Page 93 and 94: 46a not able to attend the meeting,
Page 95 and 96: 48a District 79 was 34 percent blac
Page 97 and 98: 50a considered what they were doing
Page 99 and 100: 52a African-American voters to a
Page 101 and 102: 54a 1. I serve in the South Carolin
Page 103 and 104: 56a gather for community events at
Page 105 and 106: 58a not able to attend the meeting,
Page 107 and 108: 60a District 79 was 34 percent blac
Page 109 and 110: 62a considered what they were doing
Page 111 and 112: 64a African-American voters to a
Page 113 and 114: 66a Q. So all these items would be
Page 115 and 116: 68a APPENDIX H Sellers - Direct * *
Page 117: 70a district and had some dialogue
Page 121 and 122: 74a went to committee, regardless o
Page 123 and 124: 76a know why these districts—we c
Page 125 and 126: 78a [35] Q. If there is that correl
Page 127 and 128: 80a Q. So your understanding of Gin
Page 129 and 130: 82a Q. All right. Thank you. When y
Page 131 and 132: 84a administration—Mansfield’s
Page 133 and 134: 86a would be contained in only thre
Page 135 and 136: 88a preference, according to Dave W
Page 137 and 138: 90a One of the group’s largest fe
Page 139 and 140: 92a ble. Abrams says the new maps
Page 141 and 142: 94a * * * Texas, a state not known
Page 143 and 144: 96a Conservatives want to scrub thi
Page 145 and 146: 98a “Every method that human inge
Page 147 and 148: 100a United States Code Annotated T
Page 149 and 150: 102a period which would otherwise r
Page 151: House District BVAP (2000 census
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Jurisdictional statement - About Redistricting - Loyola Law School

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