The proposed Defendat-Intervenors request that the Court grant their Motion to Intervene in this matter under Federal Rule of Civil Procedure 24.

Proposed Defendant-Intervenors request that their motion to dismiss be granted.

Lawyers Committee on Civil Rights Under Law’s answer to Plaintiff Shelby County's complaint. The Intervenor-Defendant requests that the Court enter a judgment dismissing Plaintiff's claim in its entirety, on the merits, with prejudice; denying the Plaintiff's requests for declaratory and injuctive relief in their entirety; and awarding such other and further relief as the Court may find to be just and equitable. 

Proposed Defendant-Intervenors Victoria Rodriguez, Nicole Rodriguez, Southwest Voter Registration Education Project (“Southwest Voter”) and Mi Familia Vota Education Fund (Mi Familia Vota) (collectively, “Proposed Defendant-Intervenors”), by their undersigned counsel, move the Court for leave to intervene as of right pursuant to Fed. R. Civ. P. 24(a)(2) and submit the accompanying Memorandum of Law in Support of Motion to Intervene as Defendants and Answer to Plaintiff’s First Amended Expedited Complaint in accordance with Local Civil Rule 7(j).

Defendant-intervenors' proposed supplemental, non-duplicative findings of fact and conclusions of law. 

Pursuant to Federal Rules of Civil Procedure 24(a) and 24(b), Eric Kennie, Anna Burns, Michael Montez, Penny Pope, Marc Veasy, Jane Hamilton, David de la Fuente, Lorraine Birabil, Daniel Clayton, and Sergio DeLeon (collectively “Kennie Proposed Defendant-Intervenors” or “Proposed Defendant-Intervenors”) move to intervene as Defendants in this action in order to assert positions and arguments not likely to be addressed by other parties.

Proposed Defendant-Intervenors Victoria Rodriguez, Nicole Rodriguez, Southwest Voter Registration Education Project (“Southwest Voter”) and Mi Familia Vota Education Fund (Mi Familia Vota) (collectively, “Proposed Defendant-Intervenors”), by their undersigned counsel, move the Court for leave to intervene as of right pursuant to Fed. R. Civ. P. 24(a)(2) and submit the accompanying Memorandum of Law in Support of Motion to Intervene as Defendants and Answer to Plaintiff’s First Amended Expedited Complaint in accordance with Local Civil Rule 7(j). 

Proposed Defendant-Intervenors, the Texas League of Young Voters Education Fund, Imani Clark, KiEssence Culbreath, Demariano Hill, Felicia Johnson, Dominique Monday, and Brianna Williams (collectively, “Proposed Defendant-Intervenors”), by and through their undersigned counsel, hereby submit this Motion to Intervene as of right pursuant to Fed. R. Civ. P. 24(a)(2), the accompanying Statement of Points and Authorities, and Proposed Answer in accordance with Local Civil Rule 7. 

Proposed Defendant-Intervenors Victoria Rodriguez, Nicole Rodriguez, Southwest Voter Registration Education Project (“Southwest Voter”) and Mi Familia Vota Education Fund (Mi Familia Vota) (collectively, “Proposed Defendant-Intervenors”), by their undersigned counsel, hereby respectfully move the Court for leave to intervene as of right pursuant to Fed. R. Civ. P. 24(a)(2) and submit the accompanying Memorandum of Law in Support of Motion to Intervene as Defendants and Answer to Plaintiff’s First Amended Expedited Complaint in accordance with Local Civil Rule 7(j). 

Brief filed by the Campaign Legal Center on behalf of bailed out jurisdictions in support of respondents and urging affirmance.

The amicus brief on behalf of former Directors of the U.S. Census Bureau, produced in conjunction with the Campaign Legal Center.

Plaintiffs seek declaratory and injunctive relief challenging the constitutionality of Section 5 of the Voting Rights Act of 1965, as amended in 2006 (hereinafter “Section 5”). Complaint ¶¶ 1-7, 11-37. Pursuant to 28 U.S.C. §§ 291(b), 2284 and 42 U.S.C. § 1973c(a), as well as the Court’s Local Rule 9.1, Plaintiffs apply for a three-judge court to adjudicate this action. In support of this application, Plaintiffs respectfully submit the following memorandum of points and authorities.

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. 

The Defendant requests that the Court dismiss Plaintiffs’ complaint with prejudice for lack of subject-matter jurisdiction pursuant to Fed. R. Civ. P. 12(b)(1).

Defendant asks Court to dismiss, arguing that Plaintiffs lack standing to bring their claims and, moreover, that Plaintiffs' claims are not authorized by Section 5, this Court lacks subject matter jurisdiction. 

Defendant, Attorney General of the United States (“United States”), opposes the Plaintiffs’ Application for a Three-Judge Court. Because Congress has not authorized three-judge courts to hear the constitutional claims in this case, the Plaintiffs’ application should be denied. 

District Court grants intervention. 

It is ordered that plaintiffs' application for a three-judge court is denied.