Case 1:17-Cv-03856-AT Document 1 Filed 10/03/17 Page 1 of 44
Case 1:17-cv-03856-AT Document 1 Filed 10/03/17 Page 1 of 44 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION JAMAL BROOKS, an individual; AUSTIN THOMPSON, an individual; WAYNE SWANSON, an individual; DARRYL PAYTON, an individual; AUDRA CUNNINGHAM, an individual; SABRINA MCKENZIE, an individual; JAMIDA ORANGE, an individual, ANDREA SNOW, Civil Action No. _ an individual; SAMMY ARREY-MBI; LYNNE ANDERSON, an individual; and CORETTA JACKON, an individual, Plaintiffs, Three-Judge Court Requested v. BRIAN KEMP, in his official capacity as Secretary of State of the State of Georgia, Defendant. COMPLAINT 1. Plaintiffs bring this action to challenge the Georgia General Assembly redistricting plan, Act No. 251 (2015 Ga. Laws 1413) (“H.B. 566”), on the grounds that it violates Section 2 of the Voting Rights Act of 1965, 52 U.S.C. § 10301, and the Fourteenth and Fifteenth Amendments to the United States Constitution. Through mid-cycle redistricting, the General Assembly has sought to dilute growing African-American voting strength, targeting areas where African- 1 Case 1:17-cv-03856-AT Document 1 Filed 10/03/17 Page 2 of 44 American candidates were poised to attain seats in the Georgia House of Representatives. And it has succeeded. The General Assembly not only effectively quashed the growing minority population’s voting strength in two specific House districts in the Atlanta exurbs – Districts 105 and 111 (the “Challenged Districts”) – it further circumvented the creation of at least one additional majority-minority district that would provide African-American voters the ability to elect their candidates of choice.
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