LaRoque v. Holder: Plaintiffs' Complaint

Plaintiffs request that the Court enter a judgment for the Plaintiffs (1) declaring that Section 5 unconstitutionally exceeds Congressional authority; (2) declaring that the Section 5, as amended in 2006, violates the Fifth, Fourteenth and Fifteenth Amendments to the U.S. Constitution, particularly as applied by the Attorney General, both generally and in his specific refusal to permit Kinston’s change to nonpartisan elections; (3) enjoining the Attorney General from enforcing Section 5 against Kinston’s change to nonpartisan elections; (4) enjoining any enforcement of Section 5 against Kinston in the future; and (5) any other relief the Court deems just and proper.