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McGhee v. Granville County Board of Commissioners
United States Court of Appeals for the Fourth Circuit
860 F.2d 110 (4th Cir. 1988)
African Americans comprised 43.9 percent of the population of Granville County. This demographic also comprised 40.8 percent of voting-age persons and 39.5 percent of registered voters. Originally, Granville County employed an at-large, county-wide system for electing commissioners. This system violated § 2 of the Voting Rights Act of 1965. As redress, Granville County advanced a single-member redistricting scheme. This would increase the number of commissioners to seven from the original five. Only one majority-minority district would result. Besides this, the plan would create one district potentially favorable to African American voters. Both the original scheme and this proposal featured staggered terms for commissioners. A vote-dilution challenge arose in response, on the basis of the county's plan's disproportionality. This opposition, comprised of aggrieved voters (plaintiffs), advanced a limited voting plan with at-large, nonstaggered voting. Voters would select a maximum of three candidates at their discretion. Nevertheless, voters conceded that Granville County's scheme constituted a maximal solution. The district court endorsed this plan over that of the municipality.
Rule of Law
Holding and Reasoning (Phillips, J.)
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