First, the minority group must be able to demonstrate that it is sufficiently large and geographically compact to constitute a majority in a single-member district.... Second, the minority group must be able to show that it is politically cohesive.... Third, the minority must be able to demonstrate that the white majority votes sufficiently as a bloc to enable it—in the absence of special circumstances, such as the minority candidate running unopposed ... — usually to defeat the minority's preferred candidate.
[w]hatever legislation is appropriate, that is, adapted to carry out the objects the amendments have in view, whatever tends to enforce submission to the prohibitions they contain, and to secure to all persons the enjoyment of perfect equality of civil rights and the equal protection of the laws against State denial or invasion, if not prohibited, is brought within the domain of congressional power.
[t]he plaintiffs' burden is to produce evidence to support findings that the political processes leading to nomination and election were not equally open to participation by the group in question—that its members had less opportunity than did other residents in the district to participate in the political processes and to elect legislators of their choice.
[m]ultimember districts ... violate the Equal Protection Clause, not because they overrepresent or underrepresent pure and simple, but because they do that in a context where all stages of the electoral process have been effectively closed to identifiable classes of citizens, making the political establishment “insufficiently *1026 responsive” to (Mexican–American) interests.
[t]he inherent danger in exclusive reliance on proof of motivation lies not only in the difficulties of plaintiff establishing a prima facie case of discrimination, but also in the fact that the defendants can attempt to rebut that circumstantial evidence by planting a false trail of direct evidence in the form of official resolutions, sponsorship statements and other legislative history eschewing any racial motive, and advancing other governmental objectives.
[t]he results test makes no assumptions one way or the other about the role of racial political considerations in a particular community. If plaintiffs assert that they are denied fair access to the political process, in part, because of the racial bloc voting context within which the challenged system works, they would have to prove it.
ELECTIONS INVOLVING BLACK CANDIDATES FOR COUNTY OFFICE |
---|
Election | Estimated Percentage Vote Received from White Voters | Resulting Percentage Vote Received from Black Voters |
---|
1. | May 7, 1968 | ||
School Board | |||
(1st Primary) | |||
Charles Berrium | 2.8% | 100.0% | |
2. | September 9, 1980 | ||
School Board | |||
(1st Primary) | |||
Earl Jennings | 17.0% | 44.7% | |
3. | October 7, 1980 | ||
School Board | |||
(Primary Runoff) | |||
Earl Jennings | 40.5% | 64.7% | |
4. | September 4, 1984 | ||
County Commission | |||
(1st Primary) | |||
Gregory Solomon | 18.8% | 74.7% | |
5. | October 2, 1984 | ||
County Commission | |||
(Primary Runoff) | |||
Gregory Solomon | 32.9% | 90.0% | |
6. | September 4, 1984 | ||
School Board | |||
(1st Primary) | |||
Earl Jennings | 14.5% | 78.2% |
ELECTIONS INVOLVING BLACK CANDIDATES FOR COUNTY OFFICE |
---|
Election | (Percent Vote Re- ceived by Identified Candidates Per Pre- cinct/Percent Black Voters Per Precinct) |
---|
1. | May 7, 1968 | |
School Board | ||
(1st Primary) | ||
Charles Berrium | .996 | |
2. | September 9, 1980 | |
School Board | ||
(1st Primary) | ||
Earl Jennings | .578 | |
3. | October 7, 1980 | |
School Board | ||
(Primary Runoff) | ||
Earl Jennings | .280 | |
4. | September 4, 1984 | |
County Commission | ||
(1st Primary) | ||
Gregory Solomon | .989 | |
5. | October 2, 1984 | |
County Commission | ||
(Primary Runoff) | ||
Gregory Solomon | .962 | |
6. | September 4, 1984 | |
School Board | ||
(1st Primary) | ||
Earl Jennings | .919 |
ELECTIONS INVOLVING BLACK CANDIDATES FOR NATIONAL OFFICE |
---|
7. | September 1970 | |
U.S. Senate | ||
Democratic Primary | ||
Hastings | .917 | |
8. | March 1972 | |
President | ||
Democratic Primary | ||
Chisholm | .998 | |
9. | March 1984 | |
President | ||
Democratic Primary | ||
Jackson | .983 |
ELECTIONS INVOLVING RACIAL ISSUES OR THEMES |
---|
10. | November 1968 | |
President | ||
Humphrey | ||
(vs. Nixon and Wallace) | .972 | |
11. | November 1970 | |
Governor | ||
Askew | ||
(vs. Kirk) | .847 | |
12. | March 1972 | |
Straw Ballot | ||
In Favor of Busing | .901 | |
13. | November 1972 | |
President | ||
McGovern | ||
(vs. Nixon) | .984 | |
14. | November 1976 | |
President | ||
Carter | ||
(vs. Ford) | .876 | |
15. | November 1980 | |
President | ||
Carter | ||
(vs. Reagan) | .935 | |
16. | November 1984 | |
President | ||
Mondale | ||
(vs. Reagan) | .961 |
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