Shelby County, AL v. Holder: Shelby County’s brief in support of its motion for summary judgment

Plaintiff moves the Court for entry of an Order granting summary judgment to Plaintiff. In particular, Plaintiff moves for summary judgment that Section 4(b) and Section 5 of the Voting Rights Act of 1965, as amended, are unconstitutional. Plaintiff further requests that the Court issue a permanent injunction against Defendant Attorney General Eric H. Holder, Jr., enjoining the enforcement of Section 4(b) and Section 5 of the Voting Rights Act. Plaintiff files a Memorandum of Points and Authorities, a Statement of Material Facts, the Declaration of Frank C. Ellis, Jr., a Proposed Order, and Exhibits in support of this Motion. Plaintiff also requests oral argument on this Motion.