• "The Republican House redistricting plan violates the Voting Rights Act because it intentionally dilutes minority influence throughout the state by 'packing' minorities into a few selected districts, and because it uses unconstitutional racial gerrymandering to achieve this result.

• The Republican Plan seeks to limit the influence that minorities can have on the political process over time by segregating and 'packing' African Americans into a smaller number of political districts and reducing their influence in the rest of the state.
  • African Americans are packed into 12 House districts. In each of those 12 districts, African Americans are the majority of the population. Half of those 12 districts are over 60% African American and 11 of 12 of those are over 57% African American. (If one counts voting age population, in half of the 12 districts, African Americans are over 57% of the population, and, in 10 of the 12 districts, African Americans are over 55% of the population).
  • As a result of racial packing, there is not a single House district in the Republican Plan where African Americans are between 40% and 55% of the population (if one counts voting age population, there is not a single House district where African Americans are between 35% and 53%).
  • The purpose and effect of the Republican Plan is to reduce African American influence in the rest of the Commonwealth outside these few segregated voting districts.

• The Republican plan is illegal because it is designed to ensure the political marginalization of minority groups and women statewide.

• The alternative offered by Delegate Robinson demonstrates that a redistricting plan that would comply with the Voting Rights Act can be drawn without packing minorities into a few, segregated voting districts and without diluting minority political influence. In partisan elections, minorities can -- and do -- elect candidates of their choice, even in districts where the minority voting population is less than 50%.
  • The Robinson Plan does not limit the potential for any racial group to influence the political process in Virginia. In fact, statewide, there are at least 29 'equal opportunity' districts in the plan. In each of these equal opportunity districts, minority groups constitute at least 35% of the voting age population.

• The Democrats have followed traditional race-blind redistricting criteria (compactness, contiguity, communities of interest, political fairness), and the RESULT is a Democratic Plan that creates opportunities for minority groups statewide to have an impact on the political process.

Regarding the creation of a majority-minority district in Northern Virginia.

• One result of the process and criteria followed by the Democrats in drawing our alternative redistricting plan for the House of Delegates was the natural evolution of House District 49 into a district that includes a rich diversity of people of racial and language minorities. After the Democrats released our alternative plan, the Republicans introduced amendments to their plan that included changes in their proposed House District 49 that were drawn intentionally and solely to pack racial and language minorities into the revised district and to use their self-described 'creation' of a 'majority-minority' district as a cynical excuse to pair two more incumbent Democrats into the same house district.

• As the Democratic alternative clearly demonstrates, a House District 49 can be drawn using traditional redistricting criteria without splitting communities of interest, unnecessarily dividing political jurisdictions or engaging in political gerrymandering that deprives Democrats of a fair opportunity to participate in the electoral process. Under the Republican plan, House District 49 is less compact on every measure than the Democratic alternative. For example, the perimeter of the Democratic plan is 6 miles shorter than the Republican alternative.

• The latest version of Republican House District 49 is much more highly packed with racial and language minorities than the earlier-proposed Democratic alternative, and it is more highly packed than necessary to provide the racial and language minorities living in the district an equal opportunity to elect the candidate of their choice. (Republican 70%; Democratic 62.1%). This packing, like other packing engaged in by Republicans across the state, illegally dilutes the political influence of racial and language minorities in surrounding districts" (Delegate Billy Robinson, April 12, 2001).