[EL] Analysis of the Supreme Court's North Carolina Racial Redistricting Decision

[Mark Rush]

Hi all--

A basic question:  Am I correct that, at the end of the day, North Carolina
still needs to create two majority-minority districts?  Thanks to all.

On Tue, May 23, 2017 at 1:34 PM, Nicholas Stephanopoulos <
nicholas.stephanopoulos at gmail.com> wrote:

> The way to reconcile this tension, I think, is to treat the crossover
> district as a *remedy* for a Section 2 violation (or a prophylactic
> measure against future Section 2 liability). After all, in *every *minority
> opportunity district (crossover or not), there's insufficient white bloc
> voting to defeat the minority-preferred candidate. That doesn't mean that
> Section 2 becomes inapplicable once the opportunity district is drawn; it
> means that Section 2 has been complied with through the opportunity
> district's creation.
>
> On Tue, May 23, 2017 at 12:26 PM, Pamela S Karlan <pkarlan at stanford.edu>
> wrote:
>
>> But the third prong of Gingles is not simply that there be majority-bloc
>> voting, but that that bloc voting be sufficient to defeat the minority's
>> preferred candidate.  In the example from Justice Souter, while there's
>> lots of bloc voting, it's not causing the defeat of the minority-preferred
>> candidate.
>>
>>
>> I agree with your larger point about remedies and the like.  I'm just
>> saying that it's hard simultaneously to claim that something is a crossover
>> district and that the white voters in that district vote sufficiently as a
>> bloc so as usually to defeat the minority's candidate of choice (the third
>> Gingles prong).
>>
>>
>> Pamela S. Karlan
>>
>> Kenneth and Harle Montgomery Professor of Public Interest Law
>>
>> Co-Director, Supreme Court Litigation Clinic
>>
>> Stanford Law School
>>
>> karlan at stanford.edu
>>
>> 650-725-4851 <(650)%20725-4851>
>>
>>
>> ------------------------------
>> *From:* Nicholas Stephanopoulos <nicholas.stephanopoulos at gmail.com>
>> *Sent:* Tuesday, May 23, 2017 10:22 AM
>> *To:* Pamela S Karlan
>> *Cc:* Pildes, Rick; law-election at department-lists.uci.edu
>>
>> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina
>> Racial Redistricting Decision
>>
>> It's certainly true that in *some* crossover districts (like North
>> Carolina's District 1), the third *Gingles* criterion can't be satisfied
>> because the level of crossover voting is too high. (Though I'd note that to
>> determine this with confidence, a proper racial polarization analysis would
>> be better than just data on minority population share and election
>> outcomes.) But there are clearly other crossover districts where the third
>> *Gingles* criterion can be satisfied. Here's a good example from Justice
>> Souter's dissent in *Bartlett*:
>>
>> "If a minority population with 49% of the CVAP can elect the candidate of
>> its choice with crossover by 2% of white voters, the minority 'by
>> definition' relies on white support to elect its preferred candidate. But
>> this fact alone would raise no doubt, as a matter of definition or
>> otherwise, that the majority-bloc-voting requirement could be met, since as
>> much as 98% of the majority may have voted against the minority’s candidate
>> of choice."
>>
>> Based on *Bartlett *and *Cooper*, I think it's now clear that (1) the
>> potential existence of such a crossover district isn't enough to satisfy
>> the first *Gingles* prong -- it has to be possible to draw another
>> majority-minority district; but (2) such a crossover district can be
>> created by a jurisdiction as a remedy for a Section 2 violation; and (3) if
>> such a district is dismantled, there can be liability under Section 2
>> (provided all of the *Gingles* prongs are satisfied).
>>
>> On Tue, May 23, 2017 at 11:46 AM, Pamela S Karlan <pkarlan at stanford.edu>
>> wrote:
>>
>>> The discussion on the list has been very interesting.  Nick writes that
>>>
>>> 2. Another question left open by the Court’s case law is whether
>>> crossover districts can comply with Section 2 when all three *Gingles*
>>> preconditions *are* satisfied. This precise fact pattern was not before
>>> the Court since there was insufficient white bloc voting in District 1 to
>>> meet the third *Gingles* precondition. However, the Court’s opinion
>>> hinted pretty clearly that crossover districts are acceptable Section 2
>>> remedies, even under conditions of severe racial polarization.
>>>
>>>
>>> I was a bit confused by this.  The third Gingles precondition is that "the
>>> minority must be able to demonstrate that the white majority votes
>>> sufficiently as a bloc to enable it - in the absence of special
>>> circumstances, such as the minority candidate running unopposed, . . . -
>>> usually to defeat the minority's preferred candidate."  Gingles, 478
>>> U.S. at 51.  So I'm not sure that there can *be* crossover districts in
>>> the face of the third Gingles precondition.
>>>
>>>
>>> To be sure, there can be crossover districts in the face of significant
>>> white bloc voting.  E.g., in a district where the electorate is 40% black
>>> and black voters are entirely cohesive, the black voters' candidate of
>>> choice can win even if only about 18 percent of the white electorate
>>> crosses over.  But if that crossover occurs consistently, then the third
>>> Gingles precondition won't be satisfied, will it?
>>>
>>>
>>> Pamela S. Karlan
>>>
>>> Kenneth and Harle Montgomery Professor of Public Interest Law
>>>
>>> Co-Director, Supreme Court Litigation Clinic
>>>
>>> Stanford Law School
>>>
>>> karlan at stanford.edu
>>>
>>> 650-725-4851 <(650)%20725-4851>
>>>
>>>
>>> ------------------------------
>>> *From:* law-election-bounces at department-lists.uci.edu <
>>> law-election-bounces at department-lists.uci.edu> on behalf of Pildes,
>>> Rick <pildesr at mercury.law.nyu.edu>
>>> *Sent:* Monday, May 22, 2017 3:18 PM
>>> *To:* Nicholas Stephanopoulos
>>> *Cc:* law-election at department-lists.uci.edu
>>>
>>> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina
>>> Racial Redistricting Decision
>>>
>>>
>>> For those who are not steeped in these issues, I want to point out the
>>> broad significance of the graph Nick Stephanopoulos included in his
>>> message/post.  That graph shows that the way the VRA affected districts
>>> throughout the South was to push minority voters (mainly, black voters)
>>> into two predominant types of districts:  those with a 60% minority
>>> voting-age population and those with a 20% voting-age minority population.
>>> What this did was to dramatically reduce throughout the South the number of
>>> districts in which minority voters constituted 30-50% of the voting-age
>>> population.
>>>
>>>
>>>
>>> These 30-50% minority districts were the ones that tended to elect white
>>> Democrats in the South.  As a result, the ranks of white Democrats in the
>>> South were significantly reduced, starting in the 1990s when this system
>>> went into effect.  The 20% minority population districts tended to elect
>>> Republicans.  The 60% minority districts tended to elect black Democrats.
>>>
>>>
>>>
>>> Nick’s graph, aggregated across all districts in the South, sharply
>>> illustrates this VRA-induced sorting.
>>>
>>>
>>>
>>> Richard H. Pildes
>>>
>>> Sudler Family Professor of Constitutional Law
>>>
>>> NYU School of Law
>>>
>>> 40 Washington Square South, NY, NY 10012
>>>
>>> 212 998-6377 <(212)%20998-6377>
>>>
>>>
>>>
>>> *From:* Nicholas Stephanopoulos [mailto:nicholas.stephanopoulo
>>> s at gmail.com]
>>> *Sent:* Monday, May 22, 2017 4:37 PM
>>> *To:* Pildes, Rick
>>> *Cc:* Justin Levitt; law-election at department-lists.uci.edu
>>> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina
>>> Racial Redistricting Decision
>>>
>>>
>>>
>>> A few more points to add to the analyses by Rick H., Rick P., and Justin:
>>>
>>>
>>>
>>> 1. Ever since *Gingles* itself, it has been an open question whether
>>> the mere *fact* of racial polarization in voting suffices to satisfy
>>> the case’s second and third prongs. (Justice Brennan’s opinion said yes,
>>> but it commanded only four votes on this issue. Some lower courts—including
>>> the Fifth Circuit—subsequently held that the prongs are *not* satisfied
>>> if partisanship explains racial polarization.)
>>>
>>>
>>>
>>> Today the Court strongly suggests that the causes of racial polarization
>>> are irrelevant. In the Court’s long discussion of crossover voting in
>>> District 1, it does not mention a single potential explanation for voter
>>> behavior: not partisanship, not racial animus (or its absence), not
>>> socioeconomic characteristics, not anything. Instead, the Court relies
>>> exclusively on the raw election returns, which indicate that substantial
>>> crossover voting must be occurring since black-preferred candidates
>>> consistently won elections with ~65% of the vote even though blacks made up
>>> only ~48% of District 1’s population.
>>>
>>>
>>>
>>> Going forward, I expect that Section 2 plaintiffs will be able to use
>>> the Court’s discussion as a powerful rejoinder to any argument that racial
>>> polarization should not “count” for *Gingles* purposes if it is the
>>> product of some non-racial factor. This should make it significantly easier
>>> for plaintiffs to satisfy the *Gingles* preconditions, especially in
>>> areas (like the Fifth Circuit) where courts had previously probed quite
>>> rigorously the reasons for racial polarization.
>>>
>>>
>>>
>>> 2. Another question left open by the Court’s case law is whether
>>> crossover districts can comply with Section 2 when all three *Gingles*
>>> preconditions *are* satisfied. This precise fact pattern was not before
>>> the Court since there was insufficient white bloc voting in District 1 to
>>> meet the third *Gingles* precondition. However, the Court’s opinion
>>> hinted pretty clearly that crossover districts are acceptable Section 2
>>> remedies, even under conditions of severe racial polarization. In the key
>>> passage, the Court quoted North Carolina’s position that if “§ 2 does not *require
>>> *crossover districts . . . then § 2 also cannot be *satisfied* *by*
>>> crossover districts.” This stance, declared the Court, “is at war with our
>>> § 2 jurisprudence.”
>>>
>>>
>>>
>>> Several implications follow. First, jurisdictions that are successfully
>>> sued under Section 2 should be able to design crossover districts as a
>>> remedy for the violation. Second, Section 2 suits should fail if they are
>>> used to challenge existing crossover districts (in an effort to replace
>>> them with majority-minority districts). And third, as in *Cooper*,
>>> jurisdictions should not be able to use Section 2 compliance as a defense
>>> in a racial gerrymandering case if they convert crossover districts into
>>> majority-minority districts. Arguably, all of this was implicit in
>>> *Bartlett*, but it’s still important to see the Court providing
>>> confirmation.
>>>
>>>
>>>
>>> 3. Finally, there are *many* majority-minority districts, both in the
>>> South and elsewhere in the country, where functioning crossover districts
>>> could be drawn instead. In an article
>>> <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2336749> a few
>>> years back, I created the below density curve of minority population share
>>> in all districts (congressional and state legislative) in states previously
>>> covered by Section 5. The distribution is clearly bimodal, with one of its
>>> peaks around *60%* minority voting age population. The district
>>> distribution also looks nothing like the underlying distribution of
>>> minority population share at the precinct level, which is unimodal and
>>> normal in shape. This suggests that the district distribution—with its many
>>> majority-minority districts—is the product of intentional racial
>>> redistricting.
>>>
>>>
>>>
>>> Of course, the mere fact that a crossover district could have been drawn
>>> in an area where a majority-minority district was drawn instead does not
>>> establish that race was the predominant factor in the district’s creation.
>>> The plaintiffs in *Cooper* had much more damning evidence than that,
>>> including the use of an explicit racial target. Nevertheless, it is
>>> certainly relevant that many majority-minority districts are more “packed”
>>> than they need to be to comply with Section 2—likely intentionally in many
>>> cases. This means that *Cooper*’s reach could be greater than that of
>>> the racial gerrymandering cases the Court has previously decided this cycle.
>>>
>>>
>>>
>>>  [image: Inline image 1]
>>>
>>>
>>>
>>> On Mon, May 22, 2017 at 2:18 PM, Pildes, Rick <
>>> pildesr at mercury.law.nyu.edu> wrote:
>>>
>>> Had I know Justin was posting a critique of Rick Hasen and the NC case,
>>> I would not have found a need myself to do a second post on the case to
>>> explain why I reject Rick Hasen’s analysis of the decision.  I agree with
>>> Justin’s critique on that, but I had already gone ahead and posted my
>>> similar critique, here <http://electionlawblog.org/?p=92706>, on the
>>> problems with Rick Hasen’s discussion.
>>>
>>>
>>>
>>> Best,
>>>
>>> Rick
>>>
>>>
>>>
>>> Richard H. Pildes
>>>
>>> Sudler Family Professor of Constitutional Law
>>>
>>> NYU School of Law
>>>
>>> 40 Washington Square South, NY, NY 10012
>>>
>>> 212 998-6377 <(212)%20998-6377>
>>>
>>>
>>>
>>> *From:* law-election-bounces at department-lists.uci.edu [mailto:
>>> law-election-bounces at department-lists.uci.edu] *On Behalf Of *Justin
>>> Levitt
>>> *Sent:* Monday, May 22, 2017 2:55 PM
>>> *To:* law-election at department-lists.uci.edu
>>> *Subject:* Re: [EL] Analysis of the Supreme Court's North Carolina
>>> Racial Redistricting Decision
>>>
>>>
>>>
>>> If you're looking for a reaction to the NC redistricting case from
>>> someone not named Rick, I'll offer my version, now up on the Election
>>> Law Blog <http://electionlawblog.org/?p=92700>.
>>>
>>> Though I agree with a lot of both Ricks' assessment, I pretty strongly
>>> disagree with Rick Hasen that the Court just conflated race and party.
>>> Indeed, I think that's the same sort of overly blunt, back-of-the-envelope
>>> assessment that got the legislators in North Carolina (and several
>>> other states now
>>> <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2487426>) in
>>> trouble.
>>>
>>> Instead, I think the Court "just" reiterated the notion that whether tribally
>>> partisan <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2239491>
>>> motivations are themselves permissible (more to come in both the Wisconsin
>>> case and in Part 6 of the North Carolina CD12 saga), it's unlawful to
>>> intentionally use race as the predominant and unjustified means to that
>>> end.  I put "just" in scare quotes because it's a concept that in the
>>> dilution context is quite old, but legislators seem to need fairly constant
>>> reminders.  And the fact that the Court issued yet another forceful
>>> reminder isn't a small thing.
>>>
>>> (Much) more on the blog, here <http://electionlawblog.org/?p=92700>.
>>>
>>> Justin
>>>
>>> --
>>>
>>> Justin Levitt
>>>
>>> Professor of Law
>>>
>>> Loyola Law School | Los Angeles
>>>
>>> 919 Albany St.
>>>
>>> Los Angeles, CA  90015
>>>
>>> 213-736-7417 <(213)%20736-7417>
>>>
>>> ssrn.com/author=698321
>>>
>>> @_justinlevitt_
>>>
>>> On 5/22/2017 9:32 AM, Pildes, Rick wrote:
>>>
>>> I have been asked to contribute to a SCOTUS blog Symposium on today’s
>>> North Carolina decision.  Here is the piece I have submitted, which I
>>> wanted to circulate to the list while it is in the editing process at the
>>> SCOTUS blog, for those who are trying to digest the decision now:
>>>
>>>
>>>
>>> *The Court Continues Winding Down Unnecessary Racial Redistricting  *
>>>
>>>
>>>
>>> The main take-away from today’s decision is that the Supreme Court is
>>> continuing the project of winding down unnecessary racial redistricting.
>>> The decision reflects the Court’s effort to modernize the Voting Rights Act
>>> (VRA) and ensure it adapts to the way the dynamics of race and politics
>>> have changed, in some parts of the country, in the many decades since the
>>> Act first was passed.  The crucial fact in today’s decision is that 30-40%
>>> of white voters in parts of North Carolina are willing to cross-over and
>>> vote for the same candidates that African American voters prefer – and that
>>> the VRA must reflect and recognize these changing realities.
>>>
>>>
>>>
>>> The Court today shored up the constitutional constraints limiting the
>>> use of race in redistricting, which has been the main development in the
>>> law of redistricting this decade.  That development began with the *Alabama
>>> *cases, *Alabama Legislative Black Caucus v. Alabama, *and has now been
>>> extended to Virginia and North Carolina.  And the Court also opened up a
>>> new avenue of constraint by holding that if white voters now vote for
>>> candidates black voters prefer at high enough rates, the intentional
>>> creation of majority-black districts is no longer required – and indeed, is
>>> unconstitutional.
>>>
>>> Let me situate today’s decision, before turning to its specifics, in the
>>> broader context of the Voting Rights Act and how race came to play the role
>>> it currently does in the modern era of redistricting.
>>>
>>> The regime of Voting Rights Act-required racial redistricting began in
>>> the 1990s, in the wake of Congress’ 1982 Amendments to the VRA and the
>>> Supreme Court’s 1986 decision in *Thornburg v. Gingles.  *But almost
>>> immediately after the start of that regime, beginning with the *Shaw v.
>>> Reno *line of cases, the Court has been struggling to cabin in and
>>> constrain VRA-required race-based districting to circumstances in which it
>>> is truly necessary.  In an opinion by Justice Souter back in 1994, *Johnson
>>> v. DeGrandy, *the Court wrote that race-based districting under the VRA
>>> relies “on a quintessentially race-conscious calculus aptly described as
>>> the ‘politics of the second best.’”  A majority of the Court – confirmed by
>>> the parts of today’s opinion that are unanimous – has acted on that view
>>> ever since.   If the VRA truly requires race- based districting in certain
>>> circumstances, that is fine.  But the Court has been extremely wary of
>>> extending the regime of race-based districting anywhere beyond those
>>> circumstances.
>>>
>>>
>>>
>>> Over the last 30 years, the Court has held that the VRA does not require
>>> maximizing the number of minority districts, but only ensuring that
>>> minority voters have an equal opportunity to elect their candidates of
>>> choice; it has held that the VRA does not require (and the Constitution
>>> prohibits) using irregular district shapes to create “minority opportunity”
>>> districts; it has held that the VRA does not apply if minorities cannot be
>>> made into the majority  in a district.  And with ever more force – as in
>>> today’s decision – the Court has held that the Constitution is violated if
>>> jurisdictions use the VRA to engage in race-based districting unless it is
>>> clear that the VRA clearly requires doing so.  I viewed  developments as
>>> moving in this direction back in a 2007 article, *The Decline of
>>> Legally Mandated Representation,
>>> <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1028607>* and
>>> since then, the Court’s efforts to constrain unnecessary race-based
>>> districting have become only more forceful.
>>>
>>>
>>>
>>> The most important aspect of today’s decision is the Court’s *unanimous
>>> *conclusion that Congressional District 1 (CD 1) is an unconstitutional
>>> racial gerrymander.  It would be easy to miss that this part of the opinion
>>> is unanimous, because the Court divided 5-3 on a second district at stake,
>>> CD 12.  But I have always said <https://electionlawblog.org/?p=92393>
>>> the most important issue in the NC case was that involving CD 1, and there,
>>> the Court was indeed unanimous.  And here, what is critical is that the
>>> Court rejected North Carolina’s argument that the VRA required it to create
>>> a majority-black district to make sure black voters had equal political
>>> opportunity.  More specifically, the Court concluded that voting in this
>>> area was not racially polarized enough to require the remedy of a
>>> majority-black district.
>>>
>>> What does it mean for voting to be racially polarized (RPV)?  This has
>>> been a key concept under the VRA, and yet the Court has given the concept
>>> almost no significant attention – with today’s decision being the Court’s
>>> first and thus most significant opening up of questions about this
>>> concept.
>>>
>>>
>>>
>>> When RPV first entered this area of the law, the idea was simple: if 90%
>>> of blacks vote for one candidate and 90% of whites vote for the opposing
>>> candidate (especially when the former candidate is black), there is a clear
>>> pattern of RPV.  But what happens when – as in North Carolina today –
>>> roughly 30-40% of whites are willing to vote for minority candidates?
>>> Since the VRA is only triggered in the redistricting area when voting is
>>> racially polarized, should RPV still be considered to exist in NC when
>>> there is this level of white cross-over voting support?  If the VRA still
>>> applies, how does it apply when we no longer have in NC the extreme and
>>> stark racial polarization of earlier decades?
>>>
>>>
>>>
>>> Here is how the Court resolves these issues as they come to bear in CD
>>> 1:  for the last twenty or so years, there was enough white cross-over
>>> voting support that even though the district had a black population of only
>>> 46-48%, it overwhelmingly and repeated elected a black member of Congress –
>>> typically, with 70% of the vote.  Yet North Carolina took the view that the
>>> VRA required pump up the black population above 50% to be sure the district
>>> was “safe” in ensuring for black voters an equal opportunity.  But the
>>> Court held that voting cannot be considered racially polarized if there is
>>> enough white cross-over support that black candidates are being elected
>>> from districts that are less than 50% black.
>>>
>>> This conclusion is of great significance in further unwinding
>>> unnecessary racial redistricting.  It means that the mechancial creation of
>>> majority-minority districts will no longer be constitutionally tolerated.
>>> If a cohesive black community can get its preferred candidates elected in
>>> districts that are, perhaps, only 35-40% black, then pumping those
>>> districts up to more than 50% black – on the view that the VRA requires it
>>> – will be unconstitutional.  This opens up much more space for the creation
>>> of what I have called coalitional or cross-over districts
>>> <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=304587>, in which
>>> black and white political coalitions unite behind the same candidates.
>>> Indeed, as the Court today recognized, it would turn the VRA on its head if
>>> the law actually required – as North Carolina insisted it did – that these
>>> kind of effective coalitional districts had to be turned into
>>> majority-black districts, just to ensure they are sufficiently “safe.”
>>>
>>>
>>>
>>> Put in other terms, the decision confirms that States must adhere to the
>>> view that the intentional creation of majority-minority districts is a
>>> “second best” remedial device, to be used only where clearly required.
>>> Indeed, important parts of the opinion further emphasize that, when engaged
>>> in race-based districting, States must do a thorough job of demonstrating
>>> that doing so is necessary – “the State must carefully evaluate” whether
>>> the facts support this, and the State must engage in a “meaningful
>>> legislative inquiry” about whether doing so is necessary.
>>>
>>> There are other aspects of today’s decision that will also be important
>>> in enforcing constitutional constraints on the excessive and unjustified
>>> use of race in redistricting.  The Court said, once again, that  the
>>> setting of “a racial target” that has a direct impact on the design of a
>>> district means that strict scrutiny is triggered and the district can
>>> survive only if the VRA requires it.
>>>
>>> Once again, the Court confirmed that if the State intentionally sorts
>>> voters by race into districts, the State cannot hide behind the argument
>>> that its ultimate goal was to pursue an effective partisan gerrymander.  To
>>> the extent partisan gerrymandering is constitutional, States can sort
>>> voters by their voting patterns, but not by their race.  As the Court has
>>> said before, race cannot be used as a “proxy” for political voting
>>> preferences.  To be sure, this can create a mess for the lower courts if a
>>> State does not directly and obviously use race to sort voters; the courts
>>> then have to sort out whether it was “really” race or partisan factors that
>>> drove the district’s design (I have long argued that it makes little sense
>>> for the Court to impose constitutional constraints on racial
>>> gerrymandering, but not partisan gerrymandering).
>>>
>>>
>>>
>>> There is still more in today’s decision:  The Court held that plaintiffs
>>> in these *Alabama *cases do not have provide their own alternative map
>>> (which can be a costly and time consuming venture) in order to be able to
>>> prove that a jurisdiction has engaged in race-based districting.  And there
>>> had been a confusing couple of sentences in an earlier case, also from
>>> North Carolina, that had befuddled the lower courts; the Court today
>>> confines those sentences to the particular facts of that one case, as
>>> Justice Thomas, who joined the majority, pointed out.  That is all to the
>>> good as well.
>>>
>>>
>>>
>>> In every respect of today’s decision today, then, the Court built on the *Alabama
>>> *line of cases further and made it all the more clear that the Court
>>> will aggressively police the role of race in redistricting, not permit the
>>> VRA to become a vehicle for excessively packing black voters into
>>> districts, and will continue the project of unwinding unnecessary
>>> race-based districting.
>>>
>>>
>>>
>>> Disclosure:  I argued one of the *Alabama *cases and continue to
>>> represent plaintiffs in that case, which remains pending in the lower
>>> courts.
>>>
>>>
>>>
>>> Richard H. Pildes
>>>
>>> Sudler Family Professor of Constitutional Law
>>>
>>> NYU School of Law
>>>
>>> 40 Washington Square South, NY, NY 10012
>>>
>>> 212 998-6377 <(212)%20998-6377>
>>>
>>>
>>>
>>> _______________________________________________
>>>
>>> Law-election mailing list
>>>
>>> Law-election at department-lists.uci.edu
>>>
>>> http://department-lists.uci.edu/mailman/listinfo/law-election
>>>
>>>
>>>
>>>
>>> _______________________________________________
>>> Law-election mailing list
>>> Law-election at department-lists.uci.edu
>>> http://department-lists.uci.edu/mailman/listinfo/law-election
>>>
>>>
>>>
>>>
>>>
>>> --
>>>
>>> Nicholas O. Stephanopoulos
>>> Assistant Professor of Law
>>> University of Chicago Law School
>>> nsteph at uchicago.edu
>>> (773) 702-4226
>>> http://www.law.uchicago.edu/faculty/stephanopoulos
>>>
>>
>>
>>
>> --
>> Nicholas O. Stephanopoulos
>> Assistant Professor of Law
>> University of Chicago Law School
>> nsteph at uchicago.edu
>> (773) 702-4226
>> http://www.law.uchicago.edu/faculty/stephanopoulos
>>
>
>
>
> --
> Nicholas O. Stephanopoulos
> Assistant Professor of Law
> University of Chicago Law School
> nsteph at uchicago.edu
> (773) 702-4226
> http://www.law.uchicago.edu/faculty/stephanopoulos
>
> _______________________________________________
> Law-election mailing list
> Law-election at department-lists.uci.edu
> http://department-lists.uci.edu/mailman/listinfo/law-election
>



-- 
Mark Rush
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://webshare.law.ucla.edu/Listservs/law-election/attachments/20170523/4671997d/attachment.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image001.png
Type: image/png
Size: 20682 bytes
Desc: not available
URL: <http://webshare.law.ucla.edu/Listservs/law-election/attachments/20170523/4671997d/attachment.png>