Jones v. Edwards

674 F. Supp. 1225, 1987 U.S. Dist. LEXIS 9607, 1987 WL 34
CourtDistrict Court, E.D. Louisiana
DecidedOctober 16, 1987
DocketCiv. A. 87-3864
StatusPublished
Cited by1 cases

This text of 674 F. Supp. 1225 (Jones v. Edwards) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jones v. Edwards, 674 F. Supp. 1225, 1987 U.S. Dist. LEXIS 9607, 1987 WL 34 (E.D. La. 1987).

Opinions

ORDER and REASONS

FELDMAN, District Judge.

Plaintiffs, a class of black registered voters residing in Orleans Parish, brought this action on behalf of all black registered voters similarly situated alleging violation of Section 5 of the Voting Rights Act of 1965, 42 U.S.C. § 1973c.1 Specifically, plaintiffs contend that the manner in which the Orleans Parish Registrar of Voters conducted the annual voter canvass and purge in Wards 8 and 9 of the City of New Orleans authorized by Louisiana Revised Statutes 18:192 2 and 18:1933, constituted “changes” in voter qualification within the [1227]*1227meaning of Section 5, which were not pre-cleared as required by the Act.4 Finding that there was no showing of irreparable harm because improperly purged voters could be immediately restored to the voter rolls, the single judge court denied plaintiffs’ request for a temporary restraining order enjoining the Registrar from completing the purge. Pursuant to 28 U.S.C. § 2284, the district judge then granted plaintiffs’ request that a three-judge court convene. Plaintiffs ask this three-judge Court to grant preliminary and permanent injunctive relief and all other equitable relief.

Section 5 of the Voting Rights Act provides that a covered State or political subdivision5 must take certain precautions

“[wjhenever [it] ... shall enact or seek to administer any voting qualification or prerequisite to voting, or standard, practice, or procedure with respect to voting different from that in force or effect on November 1, 1964....”

42 U.S.C. § 1973c. Before any such change can be implemented, the State or political subdivision must first obtain approval from the United States District Court for the District of Columbia or, alternatively, administratively from the Attorney General of the United States. The Attorney General may preclear a submitted change either by failing to interpose an objection within sixty days of submission, or by affirmatively indicating during the sixty day review period that an objection will not be made. Id. The option of obtaining administrative preelearance from the Attorney General [1228]*1228N.A.A.C.P. v. Hampton County Election Commission, 470 U.S. 166, 105 S.Ct. 1128, 1130 n. 1, 84 L.Ed.2d 124 (1985) (quoting McCain v. Lybrand, 465 U.S. 236, 104 5.Ct. 1037, 1044, 79 L.Ed.2d 271 (1984).

[1227]*1227“was added to the original legislation ‘to provide a speedy alternative method of compliance to covered States.’ ”

[1228]*1228By letter dated September 21,1987, after this suit was filed, the Attorney General addressed

“the alterations in the procedures and schedule for conducting the 1987 annual canvass and purge of registered voters in Wards 8 and 9 of the City of New Orleans in Orleans Parish, Louisiana....”

(Letter of Attorney General).

After reviewing the Registrar’s submissions 6, the Attorney General affirmatively indicated that he “does not interpose any objections to the changes in question.” Id. But plaintiffs could make additional submissions, if they wished. The Attorney General reserved

“the right to reexamine this submission if additional information that would otherwise require an objection comes to his attention during the remainder of the sixty-day review period.”

Id.

In view of the Attorney General’s administrative determination, plaintiffs are not now entitled to injunctive relief. The Attorney General considered the submission, indicated that the alterations in question constitute “changes” within the meaning of Section 5, and granted preclearance. Although plaintiffs attack the propriety of the administrative determination7, it is clear that such an administrative determination by the Attorney General is not judicially reviewable. Morris v. Gressette, 432 U.S. 491, 504-507, 97 S.Ct. 2411, 2420-2421, 53 L.Ed.2d 506 (1977). In Morris, the Court unequivocally insulated the administrative process from collateral attack:

“... Congress intended to provide covered jurisdictions with an expeditious alternative to declaratory judgment actions. ... Although there was to be no bar to subsequent constitutional challenges to the implemented legislation, there also was to be no dragging out of the extraordinary federal remedy beyond the period specified in the statute.”

432 U.S. at 504, 97 S.Ct. at 2420. The Morris Court concluded that Congress “intended to preclude all judicial review of the Attorney General’s exercise of discretion or failure to act.” Id. at 507 n. 24, 97 S.Ct. at 2421 n. 24. Even if the decision of the Attorney General is erroneous, it is nevertheless a determination made pursuant to the Attorney General’s Section 5 responsibilities and is nonreviewable. Id.

Plaintiffs urge that this three-judge Court nevertheless retains jurisdiction to determine whether the Registrar’s failure to obtain preclearance prior to the implementation of the canvass and purge requires us to order some equitable remedy. See N.A.A.C.P. v. Hampton County Election Commission, 470 U.S. 166, 105 S.Ct. 1128, 84 L.Ed.2d 124 (1985). In Hampton County, the Supreme Court instructed the three-judge trial court to enter an order allowing the jurisdiction to submit certain changes to the Attorney General for approval. If the county failed to make the submission or the Attorney General interposed an objection, an election held pursuant to the change would be set aside. Even if the Attorney General did preclear the change after the fact, the Supreme Court instructed that:

“[T]he District Court should determine, in the exercise of its equitable discretion, whether the results of the election may stand.”

105 S.Ct. at 1138. The Court explained that the three-judge court had

“never engaged in the equitable weighing process necessary to determine whether failure to submit a covered [1229]*1229change for preclearance requires that an election be set aside. The factors to be weighed include ‘the nature of the changes complained of, and whether it was reasonably clear at the time of the election that the changes were covered by § 5.’ ”

Id. at n. 36 (quoting Perkins v. Matthews, 400 U.S. 379, 396, 91 S.Ct. 431, 441, 27 L.Ed.2d 476 (1971)).

The Court believes that

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Related

Jones v. Edwards
674 F. Supp. 1225 (E.D. Louisiana, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
674 F. Supp. 1225, 1987 U.S. Dist. LEXIS 9607, 1987 WL 34, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-edwards-laed-1987.