MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFFS' MOTION ...

Decl. at 10-11; Rapoport Decl. at 24-25. Second, they must run actual campaignsin the pre-primary primaries in their attempt to secure delegates. See Caplan Decl. at 13-14; Campbell Decl. at 11. Third, if they’ve been successful, they are finally able torun in the primary. Finally, if successful after three campaigns, they would be able to runin the general election. This is a grueling and expensive process. It chews up theresources of the few candidates who are actually able to mount such a challenge. SeeRapoport Decl. at 26; Nielsen Decl. at 11; Caplan Decl. at 16. Yet, in single-towndistricts and every other state in the nation, candidates must run only two campaigns: theprimary and, if victorious, the general election.B. The Statistics Demonstrate the Severe Burden Imposed on Voters andCandidates in Multi-Town Districts.Forty-seven years of electoral experience illustrate the severe burdens thatConnecticut’s dual system imposes on voters in multi-town and statewide districts.1. Statewide and Congressional RacesSince 1955, when the dual system was enacted, not a single incumbentcongressman seeking re-election from one of Connecticut’s six U.S. House districts faceda primary challenge. In these 47 years, there were primaries for open seats and theoccasional primary in the party seeking to challenge the incumbent in the generalelection. See McLoughlin Decl. at Exhibit A. But of the123 times an incumbentRepresentative sought re-election in Connecticut, not one faced a primary challenge. Id.By comparison, in 2000 alone, 68 of the 403 incumbent representatives seeking reelection(or 17%) across the nation faced primary challenges; in 1998, 19% of theincumbents faced a primary challenge. See Holman Decl. at Exhibit A.14