VIA ELECTRONIC MAIL Re: Racially Polarized Voting in North Carolina and its Effect on the 2023 Redistricting Plans

Third, “the minority must be able to demonstrate that the white majority votes sufficiently as a bloc to enable it … usually to defeat the minority’s preferred candidate.”6 If these preconditions are established, the finder of fact must examine the totality of the circumstances to examine whether the vote dilution established by the preconditions is the result of discrimination. [...] Electoral performance results show that White voters are able to vote in sufficient quantity to defeat any of the Black-preferred candidates in SLD 1 and 2 of the 2023 proposed map and SLD 1 of the 2022 enacted Map. [...] All that is required is to identify the VTDs/Precincts that fall inside the electoral jurisdiction of interest (i.e., SLD 1 boundaries of the 2022 Enacted and 2023 Proposed maps) and then aggregate the candidate votes in the subject jurisdiction. [...] The left side of this figure lists the name of each contest, the year in which the elections were held, and the associated candidate names. [...] Unlike the previous results in which Black voters had the opportunity to elect their candidates of choice in SLD 3 of the Enacted Map, Black- preferred candidates lost in every single election under the Proposed SLD 1 and 2 boundaries.