2021-12-13 10:21

Proposed Intervenor Common Cause meets all the requirements under Rule 24(a)(2) of the North Carolina Rules of Civil Procedure, which permits intervention as of right “upon timely application”, “[w]hen the applicant claims an interest relating to the property or transaction which is the subject of the action and he is so situated that the disposition of the action may as a practical matter impair. [...] § 1-267.1) CAROLINA; THE NORTH CAROLINA STATE BOARD OF ELECTIONS; DAMON CIRCOSTA, in his official capacity as Chair of the State Board of Elections; STELLA ANDERSON, in her official capacity as Secretary of the State Board of Elections; STACY EGGERS IV, in his official capacity as Member of the State Board of Elections; JEFF CARMON III, in his official capacity as Member of the State Board of Elec. [...] This case is one of intentional racial discrimination in violation of the North Carolina Constitution, unconstitutional partisan gerrymandering in violation of the North Carolina Constitution, and the legal need for a reckoning with a General Assembly that has no respect for the rule of law, the rulings of the North Carolina Supreme Court, or co-equal judicial institutions at all. [...] From the beginning of this process, the Defendant Chairs of the Senate Committee on Redistricting and Elections and the House Committee on Redistricting (the “Redistricting Chairs” of the “Redistricting Committees”) have, despite warnings from citizens and legislators of color, stated their intention to contravene the North Carolina Constitution, as interpreted by the North Carolina Supreme Court. [...] These actions directly contravene the North Carolina Constitution, including: (1) the requirements of the North Carolina Constitution, which affirms the supremacy of federal law under Sections 3 and 5 of Article I; and (2) the requirement that legislators first consider the data necessary to ensure satisfaction of the requirements of federal law in drawing state legislative districts, as explained.