[EL] Analysis of the Supreme Court's North Carolina Racial Redistricting Decision
Justin Levitt
levittj at lls.edu
Tue May 23 11:44:00 PDT 2017
I think both the conversation we've been having and the North Carolina
opinion itself show that that's not quite the right question.
Perhaps a friendly amendment: the question is really whether, at the end
of the day, North Carolina needs to create two districts providing the
minority community with an opportunity to elect candidates of choice.
The election results showed that both pre-existing districts got there
without being "majority-minority."
On 5/23/2017 11:12 AM, Mark Rush wrote:
> 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
> <mailto: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 <mailto: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 <mailto:karlan at stanford.edu>
>
> 650-725-4851 <tel:%28650%29%20725-4851>
>
>
>
> ------------------------------------------------------------------------
> *From:* Nicholas Stephanopoulos
> <nicholas.stephanopoulos at gmail.com
> <mailto: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
> <mailto: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 <mailto: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 <mailto:karlan at stanford.edu>
>
> 650-725-4851 <tel:%28650%29%20725-4851>
>
>
>
> ------------------------------------------------------------------------
> *From:* law-election-bounces at department-lists.uci.edu
> <mailto:law-election-bounces at department-lists.uci.edu>
> <law-election-bounces at department-lists.uci.edu
> <mailto:law-election-bounces at department-lists.uci.edu>> on
> behalf of Pildes, Rick <pildesr at mercury.law.nyu.edu
> <mailto: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
> <mailto: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 <tel:%28212%29%20998-6377>
>
> *From:*Nicholas Stephanopoulos
> [mailto:nicholas.stephanopoulos at gmail.com
> <mailto:nicholas.stephanopoulos at gmail.com>]
> *Sent:* Monday, May 22, 2017 4:37 PM
> *To:* Pildes, Rick
> *Cc:* Justin Levitt; law-election at department-lists.uci.edu
> <mailto: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.
>
> Inline image 1
>
> On Mon, May 22, 2017 at 2:18 PM, Pildes, Rick
> <pildesr at mercury.law.nyu.edu
> <mailto: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 <tel:%28212%29%20998-6377>
>
> *From:*law-election-bounces at department-lists.uci.edu
> <mailto:law-election-bounces at department-lists.uci.edu>
> [mailto: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
> <mailto: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 <tel:%28213%29%20736-7417>
>
> ssrn.com/author=698321 <http://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 <tel:%28212%29%20998-6377>
>
>
>
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> --
>
> Nicholas O. Stephanopoulos Assistant Professor of Law
> University of Chicago Law School nsteph at uchicago.edu
> <mailto:nsteph at uchicago.edu> (773) 702-4226
> <tel:%28773%29%20702-4226>
> http://www.law.uchicago.edu/faculty/stephanopoulos
> <http://www.law.uchicago.edu/faculty/stephanopoulos>
>
> --
> Nicholas O. Stephanopoulos Assistant Professor of Law
> University of Chicago Law School nsteph at uchicago.edu
> <mailto:nsteph at uchicago.edu> (773) 702-4226
> <tel:%28773%29%20702-4226>
> http://www.law.uchicago.edu/faculty/stephanopoulos
> <http://www.law.uchicago.edu/faculty/stephanopoulos>
>
> --
> Nicholas O. Stephanopoulos Assistant Professor of Law University
> of Chicago Law School nsteph at uchicago.edu
> <mailto:nsteph at uchicago.edu> (773) 702-4226
> <tel:%28773%29%20702-4226>
> http://www.law.uchicago.edu/faculty/stephanopoulos
> <http://www.law.uchicago.edu/faculty/stephanopoulos>
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> Mark Rush
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