Dillard v. Baldwin County Commission

694 F. Supp. 836, 1988 U.S. Dist. LEXIS 10216, 1988 WL 94257
CourtDistrict Court, M.D. Alabama
DecidedJune 6, 1988
DocketCiv. A. 87-T-1159-N
StatusPublished
Cited by20 cases

This text of 694 F. Supp. 836 (Dillard v. Baldwin County Commission) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dillard v. Baldwin County Commission, 694 F. Supp. 836, 1988 U.S. Dist. LEXIS 10216, 1988 WL 94257 (M.D. Ala. 1988).

Opinion

MEMORANDUM OPINION

MYRON H. THOMPSON, District Judge.

The plaintiffs have brought this lawsuit on behalf of all black citizens in Baldwin County, Alabama. 1 They charge that the at-large system used to elect the Baldwin County Commission violates § 2 of the Voting Rights Act of 1965, as amended, 42 U.S.C.A. § 1973. 2 A violation of § 2 is established if official action was taken or maintained with a racially discriminatory “intent” or the action has racially discriminatory “results,” determined according to certain Congressionally approved criteria. McMillan v. Escambia County, 748 F.2d 1037, 1046 (5th Cir.1984) (Former Fifth); Buskey v. Oliver, 565 F.Supp. 1473, 1481 & n. 18 (M.D.Ala.1983).

The Baldwin County Commission has conceded that its at-large election system violates § 2, and thus the only issue before the court is what measures are necessary to remedy the violation. The special master in this case, United States Magistrate John L. Carroll, has recommended that the court adopt the plaintiffs’ proposed plan of seven single-member districts, rather than the county commission’s proposed plan of a “pure” at-large system. For reasons that follow, the court concludes that the magistrate’s recommendation should be adopted.

I.

Baldwin County is located in southwest Alabama. According to the 1980 census, there are 78,556 people in the county of whom 12,047, or 15.34%, are black, and 65,840, or 83.81%, are white. 3 Most of the black population is concentrated in neighborhoods on a strip along the county’s western border.

Baldwin County is currently governed by a board of four commissioners. The system used to elect the commission has three structural features particularly relevant here. First, a candidate for commissioner must run at-large, or countywide, with all voters in the county allowed to vote for the candidate. Second a candidate must run for a “numbered post” or separate place. Each commissioner position carries a separate number, and each candidate qualifies *838 for a specific number and place, with each voter allowed to vote for only one candidate in each place. 4 And third, a candidate must receive a majority of votes cast in the primary to win the nomination of a political party. If no candidate receives a majority of votes, a run-off primary election is held. The majority-vote requirement does not apply to general elections.

The Baldwin County Commission has proposed a “pure” at-large election system to cure the § 2 violation in its current system. Under the commission’s plan, elections would continue to be at-large, but the numbered-place and majority-vote components would be abandoned. The size of the commission would be increased to five.

The plaintiffs contend that the county commission’s plan does not remedy the § 2 violation, and, indeed, violates § 2. They have proposed a remedy of their own, of seven single-member districts, one of which would have a substantial majority of black voters.

II.

Congress has made clear that in determining a remedy for a § 2 violation, a

court should exercise its traditional equitable powers to fashion the relief so that it completely remedies the prior dilution of minority voting strength and fully provides equal opportunity for minority citizens to participate and to elect candidates of their choice.

S.Rep. No. 417, 97th Cong.2nd Sess. 31, reprinted in 1982 U.S.Code Cong. & Ad. News, 177, 208 (emphasis added). Thus, in the appeal of another Dillard case, the Eleventh Circuit Court of Appeals instructed that this court could not adopt any remedy that itself violates § 2, or that does not itself “completely” and “with certitude” remedy the § 2 violation. Dillard v. Crenshaw County, 831 F.2d 246, 249, 252 (11th Cir.1987). However, in exercising this broad equitable authority, a court must, whenever practicable, afford the jurisdiction an opportunity to remedy the violation first, Wise v. Liscomb, 437 U.S. 535, 540, 98 S.Ct. 2493, 2497, 57 L.Ed.2d 411 (1978), with deference accorded the jurisdiction’s plan if it provides a full, legally acceptable remedy. Tallahassee Branch of NAACP v. Leon County, 827 F.2d 1436, 1438-40 (11th Cir.1987). But if the jurisdiction fails to remedy completely the violation or if its proposed remedial plan itself violates § 2, the court must itself take measures to remedy the violation, but any court remedy must be narrowly tailored to include only those measures necessary to cure the defect. Upham v. Seamon, 456 U.S. 37, 42-43, 102 S.Ct. 1518, 1521-22, 71 L.Ed.2d 725 (1982) (per curiam).

Because the nature and scope of a required remedy depends on the nature and scope of the violation, the first issue for the court is, What exactly is the § 2 violation here? Although the Baldwin County Commission conceded liability, it did not reach an agreement with plaintiffs as to how its present election system violates § 2. Fortunately, the at-large system used by the commission is the same as the one used by the county school board, and this court recently addressed in some detail in another, companion case involving the school board, just how the system violates § 2. 5 Dillard v. Baldwin County Board of Education, 686 F.Supp. 1459 (M.D.Ala. 1988). 6

Much abridged, the holdings and findings of the court in the school board case were as follows. First, the court held that the at-large scheme was a product of “intentional” racial discrimination. The evidence reflected that, for the purpose of minimizing black voting strength, the Alabama legislature reshaped local at-large election *839 schemes by enacting “anti-single shot” laws in the 1950’s and by replacing those laws in 1961 with “numbered place” laws. The evidence also established that the legislature engaged in a century-long pattern and practice of switching between local at-large election systems and local single-member district systems as needed to diminish black voting strength. Baldwin County Board of Education, 686 F.Supp. at 1467-69; see also Dillard v. Crenshaw County, 640 F.Supp. 1347 (M.D.Ala.1986). The court went on to conclude that the at-large system used by the school board was a product of both invidious schemes and that the at-large system was still having its intended racist effect. Baldwin County Board of Education, 686 F.Supp. at 1468.

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686 So. 2d 220 (Supreme Court of Alabama, 1996)
Southern Christian Leadership Conference v. Sessions
56 F.3d 1281 (Eleventh Circuit, 1995)
White v. State of Ala.
867 F. Supp. 1519 (M.D. Alabama, 1994)
Concerned Citizens for Equality v. McDonald
863 F. Supp. 393 (E.D. Texas, 1994)
Dillard v. Crenshaw County
748 F. Supp. 819 (M.D. Alabama, 1990)
Dillard v. Baldwin County Comm.
862 F.2d 878 (Eleventh Circuit, 1988)
Dillard v. Chilton County Board of Education
699 F. Supp. 870 (M.D. Alabama, 1988)

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Bluebook (online)
694 F. Supp. 836, 1988 U.S. Dist. LEXIS 10216, 1988 WL 94257, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dillard-v-baldwin-county-commission-almd-1988.