Stationary Distribution of Recombination on 4X4 Grid Graph As It Relates to Gerrymandering
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Plaintiff's Motion for the Court to Issue Direction To
STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION COUNTY OF WAKE 18CVS 014001 COMMON CAUSE,etal, Plaintiffs, PLAINTIFFS' MOTION FOR THE COURT TO ISSUE DIRECTION TO LEGISLATIVE DEFENDANTS DAVID LEWIS,IN HIS OFFICIAL CAPACITY AS SENIOR CHAIRMAN OF THE HOUSE SELECT COMMITTEE ON REDISTRICTING, et al., Defendants. m a EXHIBIT A STEPHANIE HOFELLER May 17, 2019 STATE OF NORTH CAROLINA GENERAL COURT OF JUSTICE 1 A P P E A R A N C E S (continued) SUPERIOR COURT DIVISION 2 Counsel for the Defendant-Intervenors: COUNTY OF WAKE 18 CVS 014001 3 Shanahan Law Group BY: John E. Branch, III COMMON CAUSE, ET AL., ) 4 128 E. Hargett Street, Suite 300 ) Raleigh, North Carolina 27601 Plaintiffs, ) 5 (919) 856-9494 ) [email protected] vs. ) 6 ) Counsel for the Deponent: DAVID LEWIS, IN HIS OFFICIAL ) 7 CAPACITY AS SENIOR CHAIRMAN ) Fiduciary Litigation Group OF THE HOUSE SELECT COMMITTEE ) 8 BY: Tom Sparks ON REDISTRICTING, ET AL., ) 223 South West Street, Suite 900 ) 9 Raleigh, North Carolina 27603 Defendants. ) (919) 229-0845 10 [email protected] 11 VIDEOTAPED DEPOSITION OF 12 Also Present: Trae Howerton, Videographer STEPHANIE HOFELLER 13 ________________________________________________ 14 9:38 A.M. 15 FRIDAY, MAY 17, 2019 16 Reported By: Discovery Court Reporters and Legal ________________________________________________ Videographers 17 BY: Lisa A. Wheeler, RPR, CRR POYNER SPRUILL 4208 Six Forks Road, Suite 1000 18 Raleigh, North Carolina 27609 301 FAYETTEVILLE STREET, SUITE 1900 (919) 649-9998 19 RALEIGH, NORTH CAROLINA --oOo-- 20 21 22 23 BY: LISA A. WHEELER, RPR, CRR 24 25 1 3 1 A P P E A R A N C E S 1 I N D E X 2 Counsel for the Plaintiffs: PAGE 3 Arnold & Porter Kaye Scholer 2 BY: R. -
Computer Models and Post-Bandemer Redistricting
Computer Models and Post-Bandemer Redistricting Michelle H. Browdy Since the Supreme Court first held political redistricting1 to be justicia- ble in Baker v. Carr,2 legal challenges to districting plans have increased dramatically.3 Because the Court's 1986 decision in Davis v. Bandemer4 held partisan gerrymandering5 to be justiciable for the first time,6 even more litigation will likely accompany redistricting following the 1990 cen- 1. States are divided into geographical districts from which representatives are elected either for the United States House of Representatives or for state legislative bodies. Political redistricting occurs when states redraw their political boundary lines after each decennial census. Since the benefits and detriments of automated redistricting apply equally to both congressional and state legislative redis- triting, this Note will not distinguish between them. The Supreme Court, however, does treat chal- lenges to the two types of districts differently, applying tighter standards of population equality to congressional districts than to state legislative districts. Compare Karcher v. Daggett, 462 U.S. 725 (1983) (invalidating plan for New Jersey's congressional districts with average deviation from perfect population equality of 0.1384%) with Brown v. Thomson, 462 U.S. 835 (1983) (upholding plan for Wyoming state legislature with maximum population deviation of 89%). 2. 369 U.S. 186 (1962). In Baker, the Court held that a challenge to the disparity of population size in districts of the Tennessee General Assembly was justiciable under the equal protection clause, U.S. CoN sT. amend XIV, § 1. A previous challenge to the lack of population equality in districts in Illinois had been held nonjusticiable when it was brought under the guaranty clause, U.S. -
Joseph Weekdays from June 11 to Aug
CMYK Are you a poor What’s all the communicator? buzz about? Check out conversation traps You can get a free preview you could be stumbling into of Microsoft’s Windows 8 HEALTH, 1C BUSINESS, 7B 759802 The Times Leader WILKES-BARRE, PA timesleader.com TUESDAY,JUNE 5, 2012 50¢ SPORTS PENN STATE ABUSE SCANDAL SHOWCASE Homestead tax break going up The removal of ineligible properties will increase the assistance for others. By JENNIFER LEARN-ANDES [email protected] Sharapova advances Luzerne County school dis- at Open tricts will receive a combined $11.8 million in gambling reve- After dropping a total nue to reduce property taxes on of five games in three primary residences this year, a matches that averaged new state estimate shows. The overall allocation to coun- less than an hour each, ty districts has remained about Maria Sharapova the same since the gambling- moved into the quar- funded breaks started with 2008- 09 school tax bills. terfinals at the only The owners of 84,340 primary AP PHOTO/CENTRE DAILY TIMES, NABIL K. MARK Grand Slam tourna- residences eligible for the home- Media trucks line Allegheny Street in front of the Centre County Courthouse in downtown Bellefonte on Monday. Jury se- ment she hasn’t won stead/farmstead break will pay lection in the Jerry Sandusky sexual abuse trial is scheduled for today. $52 to $212 less for school taxes, by dispensing with depending on the district, the tactics and swinging state says. Elimination of more away until she finally than 3,500 ineligible households pulled out a 6-4, 6-7 by the county and school districts boosts the individual credit (5), 6-2 victory over slightly. -
Pa Democratic Party, Et Al
133 MM 2020 IN THE SUPREME COURT OF PENNSYLVANIA MIDDLE DISTRICT PENNSYLVANIA DEMOCRATIC ) PARTY; et al., ) ) Petitioners, ) ) v. ) 133 MM 2020 ) ) KATHY BOOCKVAR; et al., ) ) Respondents. ) APPENDIX TO PETITIONERS’ BRIEF Exhibit Description of Document A Petitioners Omnibus Memorandum of Law in Opposition to Preliminary Objections of Various County Boards of Elections B Petitioners’ Answers to Various Boards of Elections and Secretary of the Commonwealth’s New Matters C Application for Mail-In Ballot D Declaration of Adam R. Roseman, Esq. E August 31, 2020 transcript of the evidentiary hearing in Crossey (“Crossey Transcript”). F August 1, 2020 Pennsylvania 2020 Primary Election Act 35 of 2020 Report G January 10, 2020 Department of State Mail-in and Absentee Ballots and Voter Registration Changes Guidance 1 ReceivedFiled 9/8/2020 4:43:554:43:00 PM Supreme Court Middle District H August 19, 2020 Department of State Absentee and Mail-in Ballot Return Guidance I May 28, 2020 email from the Deputy Secretary of State Jonathan Marks to county Boards of Election J August 19, 2020 Department of State Guidance for Missing Official Election Ballot Envelopes K Petitioners’ Exhibit 32 admitted into evidence during the Crossey hearing (“Stroman Report”). L Relevant portions of Philadelphia County Board of Elections’ Objections and Responses to Plaintiffs’ First Set of Interrogatories and Requests for Production in the case captioned Donald J. Trump for President, Inc., et al v. Boockvar, et al, No. 20-966 (W.D. Pa.) (“Federal Court Act”). M Relevant portions of Bucks, Chester, and Montgomery County Boards of Elections’ Objections and Responses to Plaintiffs’ First Set of Interrogatories and Request for Production in the Federal Court Action. -
Senator Joe Scarnati, President Pro Tempore
SENATE LEADERSHIP 2019-2020 Senator Joe Scarnati, President Pro Tempore As President Pro Tempore of the Senate, he holds the third-highest constitutional office in the State. He was born and raised in Brockway, Pennsylvania and represents the 25th Senatorial District, which includes Cameron, Clinton, Elk, Jefferson, McKean, Potter and Tioga Counties and portions of Clearfield County. Joe grew up understanding that business and industry are vital to our state’s economy and its future. After graduating from Penn State University at DuBois, Joe became a third-generation business owner in the Brockway area. He has carried on the lifelong tradition of working to better his community through involvement and civic leadership, serving on both the Brockway Borough Council and the Jefferson County Development Council. He is also a member of the St. Tobias Roman Catholic Church in Brockway. Working in the private sector for 20 years prior to coming to Harrisburg, serving as a local official and being a small business owner have given him a unique perspective on how government can work more effectively to help job-creators, working families and communities. Since being elected to office, Joe has been a leader in reforming the way business is conducted in Harrisburg, and he remains committed to making the institution more open and accessible to the citizens of the Commonwealth. As Senate President Pro Tempore, Joe serves as an ex-officio member of each of the 22 Senate Committees. He has been a committed leader in addressing numerous important fiscal and conservative issues within the state. In his 17 years as a State Senator, Joe has served as a rank and file member of the Senate, as a member of Senate Leadership and currently as Senate President Pro Tempore – a position that he was elected to by the full Senate. -
Legislative Journal
COMMONWEALTH OF PENNSYLVANIA Legislative Journal TUESDAY, JANUARY 1, 2013 SESSION OF 2013 197TH OF THE GENERAL ASSEMBLY No. 1 SENATE (Whereupon, the Senate en bloc stood in a moment of silence in solemn respect to the memory of the VICTIMS OF SANDY TUESDAY, January 1, 2013 HOOK ELEMENTARY SCHOOL, Newtown, Connecticut.) The PRESIDENT. This is the constitutional day and hour for PRESENTATION OF ELECTION RETURNS the convening of the 197th Regular Session of the General As- sembly. The PRESIDENT. The Chair recognizes the Sergeant-at- Arms. The PRESIDENT (Lieutenant Governor Jim Cawley) called The SERGEANT-AT-ARMS. Mr. President, I have the honor the Senate to order at 12 m., Eastern Standard Time. to present the Secretary of the Commonwealth, the Honorable PRAYER Carol Aichele. Secretary AICHELE. Mr. President, I have the honor to pres- The Chaplain, Reverend MARTIN D. ODOM, Pastor of ent the official returns and statements of campaign expense com- Bethel Village A.M.E. Church, Harrisburg, offered the following pliance for the offices of Attorney General, Auditor General, prayer: State Treasurer, and Senators in the General Assembly for the election held November 6, 2012. Let us pray. The PRESIDENT. The Chair thanks Secretary Aichele. The Eternal God, Creator and Sustainer of all humankind, we returns for Treasurer, Auditor General, and Attorney General thank You for this day that You have made. We thank You for will lie on the table. this opportunity that You have given us to serve, to make a meaningful difference in the lives of those whom You have ELECTION RETURNS OF SENATORS called each and all of us to help and uplift. -
Districting Criteria and a Proposal for Their Empirical Redefinition
GERRYMANDERED BY DEFINITION: THE DISTORTION OF “TRADITIONAL” DISTRICTING CRITERIA AND A PROPOSAL FOR THEIR EMPIRICAL REDEFINITION YUNSIEG P. KIM* & JOWEI CHEN† What are “traditional” districting criteria? The meaning of that term is critical to curbing abusive districting practices because adherence to traditional criteria grants districting plans a prima facie impression of constitutionality and serves as a strong defense to racial gerrymandering claims. Yet, the Supreme Court has never intelligibly defined “traditional” districting criteria or its indicative qualities. Exploiting this silence, various actors are attempting to define that term in service of their own interests, usually at the expense of the public’s. For example, legislatures pushing redistricting plans that would advantage certain parties or incumbents claim that those districting goals are “traditional”—and therefore must be judicially protected—by relying on anecdotal examples of a state having used them. This Article proposes a definition of “traditional” districting criteria that would both reduce such abuse and adhere to a commonly understood meaning of that word: widely accepted as standard practice. Under this alternative, which we call the empirical definition, a criterion is “traditional” only if a majority of states require or allow it and fewer than a quarter prohibit it in state constitutions, statutes, or legislative guidelines. According to the empirical definition and our database of the fifty states’ redistricting laws, compactness, contiguity, equal population, and preserving county and city boundaries are traditional criteria. Among others, partisan advantage, incumbent protection, and preserving communities of interest are nontraditional. The empirical definition would not only curb abusive districting but also reduce the influence of undesirable judicial activism by binding judges’ discretion to an objectively discernible definition of “traditional” criteria. -
RUCHO V. COMMON CAUSE
(Slip Opinion) OCTOBER TERM, 2018 1 Syllabus NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337. SUPREME COURT OF THE UNITED STATES Syllabus RUCHO ET AL. v. COMMON CAUSE ET AL. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA No. 18–422. Argued March 26, 2019—Decided June 27, 2019* Voters and other plaintiffs in North Carolina and Maryland filed suits challenging their States’ congressional districting maps as unconsti- tutional partisan gerrymanders. The North Carolina plaintiffs claimed that the State’s districting plan discriminated against Demo- crats, while the Maryland plaintiffs claimed that their State’s plan discriminated against Republicans. The plaintiffs alleged violations of the First Amendment, the Equal Protection Clause of the Four- teenth Amendment, the Elections Clause, and Article I, §2. The Dis- trict Courts in both cases ruled in favor of the plaintiffs, and the de- fendants appealed directly to this Court. Held: Partisan gerrymandering claims present political questions be- yond the reach of the federal courts. Pp. 6–34. (a) In these cases, the Court is asked to decide an important ques- tion of constitutional law. Before it does so, the Court “must find that the question is presented in a ‘case’ or ‘controversy’ that is . -
In the United States District Court for the District of Marland Greenbelt Division
Case 8:11-cv-03220-RWT Document 43-16 Filed 12/07/11 Page 1 of 53 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARLAND GREENBELT DIVISION MS.PATRICIA FLETCHER, ) et al., ) ) Civ. Action No.: RWT-11-3220 ) Plaintiffs, ) ) v. ) ) LINDA LAMONE in her official ) capacity as State Administrator of ) Elections for the state of Maryland; ) And ROBERT L. WALKER in his ) official capacity as Chairman of the ) State Board of Elections, ) ) Defendants. ) _____________________________________) DECLARATION AND EXPERT REPORT OF RONALD KEITH GADDIE, Ph.D. Case 8:11-cv-03220-RWT Document 43-16 Filed 12/07/11 Page 2 of 53 DECLARATION OF RONALD KEITH GADDIE I, Ronald Keith Gaddie, being competent to testify, hereby affirm on my personal knowledge as follows: 1. My name is Ronald Keith Gaddie. I reside at 3801 Chamberlyne Way, Norman, Oklahoma, 73072. I have been retained as an expert to provide analysis of the Maryland congressional districts by counsel for the Fannie Lou Hamer Coalition. I am being compensated at a rate of $300.00 per hour. I am a tenured professor of political science at the University of Oklahoma. I teach courses on electoral politics, research methods, and southern politics at the undergraduate and graduate level. I am also the general editor (with Kelly Damphousse) of the journal Social Science Quarterly. I am the author or coauthor of several books, journal articles, law review articles, and book chapters and papers on aspects of elections, including most recently The Triumph of Voting Rights in the South. In the last decade I have worked on redistricting cases in several states, and I provided previous expert testimony on voting rights, redistricting, and statistical issues. -
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Case 3:18-cv-01865-RS Document 214 Filed 05/30/19 Page 1 of 5 1 XAVIER BECERRA Attorney General of California 2 MARK R. BECKINGTON ANTHONY R. HAKL 3 Supervising Deputy Attorneys General GABRIELLE D. BOUTIN, SBN 267308 4 R. MATTHEW WISE, SBN 238485 ANNA T. FERRARI, SBN 261579 5 TODD GRABARSKY, SBN 286999 NOREEN P. SKELLY, SBN 186135 6 Deputy Attorneys General 1300 I Street, Suite 125 7 P.O. Box 944255 Sacramento, CA 94244-2550 8 Telephone: (916) 210-6053 Fax: (916) 324-8835 9 E-mail: [email protected] Attorneys for Plaintiff State of California, by and 10 through Attorney General Xavier Becerra 11 IN THE UNITED STATES DISTRICT COURT 12 FOR THE NORTHERN DISTRICT OF CALIFORNIA 13 SAN FRANCISCO DIVISION 14 15 STATE OF CALIFORNIA, et al. Case No. 18-cv-01865-RS 16 Plaintiffs, 18-cv-02279-RS 17 v. 18 NOTICE OF PROCEEDINGS IN WILBUR L. ROSS, et al., RELATED ACTION 19 Defendants. 20 ------------------------------------------------------ 21 CITY OF SAN JOSE, et al., 22 Plaintiffs, 23 v. 24 WILBUR L. ROSS, et al., 25 Defendants. 26 27 28 Case 3:18-cv-01865-RS Document 214 Filed 05/30/19 Page 2 of 5 1 The plaintiffs in the above-captioned cases respectfully provide notice to the Court of 2 proceedings in the related action of State of New York v. U.S. Department of Commerce, 18-CV- 3 2921 in the United States Court for the Southern District of New York (New York action). 4 On May 30, 2019, certain plaintiffs in the New York action filed in the district court a 5 request for an order to show cause whether sanctions or other appropriate relief are warranted in 6 light of new evidence contradicting sworn deposition testimony in that case. -
Forging Our Future Together: Addressing Rural and Urban Needs to Build a Stronger Region
D ECTE OFFIC EL IA L LS A R U E N T N R A d E r A 3 FORGING T 2 OUR FUTURE TOGETHER: ADDRESSING RURAL AND URBAN S NEEDS TO BUILD E B P A STRONGER U T L E REGION C M Y B T E I R S R 19 VE /2 NI 0, 2019 | U Hosted by the University of Pittsburgh Office of the Chancellor and the Institute of Politics UNIVERSITY OF PITTSBURGH OFFICE OF THE CHANCELLOR and INSTITUTE OF POLITICS welcome you to the TWENTY-THIRD ANNUAL ELECTED OFFICIALS RETREAT Forging Our Future Together: Addressing Rural and Urban Needs to Build a Stronger Region September 19-20, 2019 University Club If you have questions about the materials or any aspect of the program, please inquire at the registration desk. Contents About the Institute ........................................................................................................................................ 3 Director’s Note .............................................................................................................................................. 5 Retreat Agenda ............................................................................................................................................. 7 2019 Coleman Award Winner – Frederick W. Thieman ............................................................................. 10 Speaker and Panelist Biographies ............................................................................................................... 11 IOP Program Criteria and Strategies .......................................................................................................... -
Amicus Brief of the Brennan Center for Justice in Support of Petitioners
IN THE SUPREME COURT OF PENNSYLVANIA NO. 159 MM 2017 League of Women Voters of Pennsylvania, Carmen Febo San Miguel, James Solomon, John Greiner, John Capowski, Gretchen Brandt, Thomas Rentschler, Mary Elizabeth Lawn, Lisa Isaacs, Don Lancaster, Jordi Comas, Robert Smith, William Marx, Richard Mantell, Priscilla Mcnulty, Thomas Ulrich, Robert Mckinstry, Mark Lichty, Lorraine Petrosky, Petitioners, v. The Commonwealth of Pennsylvania; the Pennsylvania General Assembly; Thomas W. Wolf, In His Capacity as Governor of Pennsylvania; Michael J. Stack III, In His Capacity As Lieutenant Governor of Pennsylvania and President of the Pennsylvania Senate; Michael C Turzai, In His Capacity As Speaker of the Pennsylvania House of Representatives; Joseph B. Scarnati III, In His Capacity As Pennsylvania Senate President Pro Tempore; Robert Torres, In His Capacity As Acting Secretary of the Commonwealth of Pennsylvania; Jonathan M. Marks, In His Capacity As Commissioner of the Bureau Of Commissions, Elections, and Legislation of the Pennsylvania Department of State, Respondents. BRIEF OF AMICUS CURIAE THE BRENNAN CENTER FOR JUSTICE AT NEW YORK UNIVERSITY SCHOOL OF LAW IN SUPPORT OF PETITIONERS On Consideration from the Commonwealth Court of Pennsylvania Civ. No. 261 MD 2017 On the brief: Richard L. Bazelon (PA No. 02505) A. Richard Feldman (PA No. 41329) Laura W. Brill Lisa A. Barton (PA No. 78139) Nicholas Daum Bazelon, Less & Feldman, P.C. Kendall Brill & Kelly LLP One South Broad Street, Suite 1500 10100 Santa Monica Blvd. #1725 Philadelphia, PA 19107 Los Angeles, CA (215) 568-1155 Michael C. Li Attorneys for Amicus Curiae Thomas P. Wolf The Brennan Center for Justice The Brennan Center for Justice at New York University 120 Broadway, Suite 1750 School of Law New York, NY TABLE OF CONTENTS TABLE OF AUTHORITIES ...................................................................................