Redistricting Lawsuit

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IN THE STATE OF MICHIGAN

IN THE SUPREME COURT

State Representative Tenisha Yancey, State of


MI, Detroit Caucus Chair, House District 1, Supreme Court Case No.
Former State Representative & Detroit
Caucus Chair Sherry Gay-Dagnogo, M.Ed.,
DPSCD Board Member, Senator Betty Jean Jurisdiction:
Alexander, Senate District 5, Former State
Rep. Teola P. Hunter, First Female Speaker
Pro Tem, Romulus City Council Member
Virginia Williams, Vice Pro Tem, Hon. Keith VERIFIED COMPLAINT
Williams, Chair MDP Black Caucus, Natalie
Bienaime, Citizen the 13th District, Dr. Carol
Weaver, 14th Congressional District
Executive Board Member, State
Representative Tyrone Carter, District 6, Vice
Chair Detroit Caucus State Rep., Helena
P: (313) 983-4600 | F: (313) 983-4665
AYAD LAW, P.L.L.C.

Scott, District 7 State Rep., Stephanie Young,


645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

8th District, Rep. Mary Cavanagh, 10th


District,

Plaintiffs,

v.

INDEPENDENT CITIZENS
REDISTRICTING COMMISSION,

Defendant.

AYAD LAW, PLLC


Nabih H. Ayad (P59518)
William D. Savage (P82146)
Attorney for Plaintiff
645 Griswold St., Ste 2202
Detroit, MI 48226
P: 313.983.4600
F: 313.983.4665
[email protected]
[email protected]

1|Page
VERIFIED COMPLAINT

NOW COMES, the above-named Plaintiffs (hereinafter "Plaintiffs"), by and through their

attorneys at Ayad Law, PLLC, and hereby make the following complaint:

INTRODUCTION

1. On November 6, 2018, Michiganders voted to amend the Michigan Constitution of 1963

to create the Michigan Redistricting Commission (hereinafter "Defendant" or "the

Commission").

2. After being created, the Commission has maintained that its mission and vision are:

Mission: To lead Michigan's redistricting process to assure Michigan's


Congressional, State Senate, and State House district lines are drawn fairly
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AYAD LAW, P.L.L.C.

in a citizen-led, transparent process, meeting Constitutional mandates.


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DETROIT, MICHIGAN 48226

Vision: To chart a positive course for elections based on fair maps for
Michigan today and for the future.

(See https://www.michigan.gov/micrc/0,10083,7-418-92033---,00.html,
last visited January 3, 2022, emphasis in original.)

3. This Supreme Court has already ruled that the Commission failed in its self-stated mission

of 'transparency' when on December 20, 2021, it ruled that the Commission had violated

Michigan's Open Meetings Act, and ordered the commission to make public the meetings

they had been having in private.

4. On December 28, 2021, the Commission officially approved its redistricting maps (or

"Plans") for the state of Michigan's Congressional, State Senate, and State House district

voter districts.

5. It is clear from the Commission's current proposed Plans that they will also be falling

woefully short of their vision: "To chart a positive course for elections based on fair maps

for Michigan today and for the future."

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6. Michigan Redistricting Commission was sold to the Michigan voter as a means of reducing

gerrymandering in the redistricting of Michigan's voter districts following the 2021 census.

However, the idea of an impartial, non-discriminatory, non-racist redistricting plan has

been shattered by the revelation of the Michigan Redistricting Commissions Plans.

7. The new Plans, with their new voting district maps, were backed by eight out of thirteen

of the randomly selected voters who serve on the commission.

8. Should the Plans be adopted, it would completely eliminate the two majority-minority

(Black) districts that currently run through Detroit. Instead, those districts would be

apportioned into eight new districts comprised of eight small sections of Detroit, each
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AYAD LAW, P.L.L.C.

paired with a large section of a Detroit suburb.


645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

9. Each of the new eight districts would be majority-White.

10. Such redistricting would completely rob the Black minority of Southeastern Michigan, and

therefore the City of Detroit, of its ability to elect their chosen representatives into office.

11. This practice of splintering a majority-minority voter district is termed "dilution" and has

long been banned by federal law pursuant to the Voting Rights Act of 1965.

12. The Voting Rights Act of 1965 was the first federal legislation to outlaw intimidation and

other barriers to voting of African Americans and other racial minorities. Since that victory

of the Civil Rights Movement, Black Americans have had the highest voting rate of any

racial group in the nation.1

13. The Commission's redistricting is a blatant and obvious "retrogression" of the national and

Michigan Civil Rights Movement and sets-back the Black population of Michigan

generations by undoing the hard-fought representation achieved by Detroiters and the

Black community in Michigan over the last 70 years.

1
https://www.census.gov/newsroom/blogs/random-samplings/2017/05/voting_in_america.html

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14. As the United States Supreme Court has stated:

The maintenance of existing district boundaries is advantageous to both


voters and candidates. Changes, of course, must be made after every census
to equalize the population of each district or to accommodate changes in the
size of a State's congressional delegation. Similarly, changes must be made
in response to a finding that a districting plan violates § 2 or § 5 of the
Voting Rights Act, [52 USCA §§ 10301, 10304(b, d)]. But the interests in
orderly campaigning and voting, as well as in maintaining communication
between representatives and their constituents, underscore the importance
of requiring that any decision to redraw district boundaries—like any other
state action that affects the electoral process—must, at the very least,
serve some legitimate governmental purpose. See, e.g., Burdick v.
Takushi, 504 U.S. 428, 434, 440, 112 S.Ct. 2059, 119 L.Ed.2d 245 (1992);
id., at 448–450, 112 S.Ct. 2059 (KENNEDY, J., joined by Blackmun and
STEVENS, JJ., dissenting).

League of United Latin Am Citizens v Perry, 548 US 399, 448; 126 S Ct


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AYAD LAW, P.L.L.C.

2594, 2626–27; 165 L Ed 2d 609 (2006) (emphasis added).


645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

15. Here, the destruction of Detroiters and Black voters ability to elect their preferred

representatives and/or minority candidates could serve no legitimate government

purpose, and therefore, it violates Michigan Constitution, the United States

Constitution, and the Voting Rights Act of 1965.

THE PARTIES

16. Plaintiffs are all African-American, and residents of city of Detroit, MI, besides Plaintiff

Hunter, who resides in Romulus, MI.

a. State Representative Tenisha Yancey, State of MI, Detroit Caucus Chair, House

District 1, resident of Michigan;

b. Former State Representative & Detroit Caucus Chair Sherry Gay-Dagnogo, M.Ed.,

DPSCD Board Member, resident of Michigan;

c. Senator Betty Jean Alexander, Senate District 5, resident of Michigan;

d. Former State Rep. Teola P. Hunter, First Female Speaker Pro Tem, resident of

Michigan;

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e. Romulus City Council Member Virginia Williams, Vice Pro Tem, resident of

Michigan;

f. Hon. Keith Williams, Chair MDP Black Caucus, resident of Michigan;

g. Natalie Bienaime, Citizen the 13th District, resident of Michigan;

h. Dr. Carol Weaver, 14th Congressional District Executive Board Member, resident

of Michigan;

i. State Representative Tyrone Carter, District 6, Vice Chair Detroit Caucus, resident

of Michigan;

j. State Rep., Helena Scott, District 7, resident of Michigan;


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AYAD LAW, P.L.L.C.

k. State Rep., Stephanie Young, 8th District, resident of Michigan;


645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

l. Rep. Mary Cavanagh, 10th District, resident of Michigan.

17. Defendant Independent Citizens Redistricting Commission (“ICRC”) is a permanent

commission in the legislative branch of government. Const 1963, art 4, § 6(1).

JURISDICTION

18. The Court has original subject-matter jurisdiction over this action under Article IV, Section

19, of the Michigan Constitution of 1963.

19. The Court also has subject-matter jurisdiction under Section 217(3) of the Revised

Judicature Act, MCL 600.217(3), and Michigan Court Rules 3.301(A)(1)(c) and (g) and

Michigan Court Rule 3.305(A)(2).

20. The Court has general personal jurisdiction over Plaintiffs under Section 701(3) of the

Revised Judicature Act, MCL 600.701(3).

21. The Court has general personal jurisdiction over the Commission under Section 2051(4) of

the Revised Judicature Act, MCL 600.2051(4).

FACTUAL BACKGROUND

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22. According to the U.S. Census Bureau, Black or African Americans living in Detroit

accounted for 79.1% of the total population, or approximately 532,425 people as of 2017

estimates.2

23. According to the 2000 U.S. Census, of all U.S. cities with 100,000 or more people, Detroit

had the second-highest percentage of Black people.3

24. Biden won the city of Detroit with 94% of the vote while Trump received 5%, according

to the city of Detroit's election results.4

25. Yet statewide in Michigan, Biden defeated Trump by merely 50.6% to 47.9% (voter

turnout was 71%).


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AYAD LAW, P.L.L.C.

26. These numbers make undeniably clear that the Black population of Detroit, Michigan, is a
645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

community of interest, which has its own preferred political candidates and which, when

districts are mapped fairly, has the power to elect the representatives of their choice.

27. Michigan voters supported establishing an Independent Citizens Redistricting Commission

in 2018 on the premise it would eliminate “gerrymandering” in the creation of legislative

and congressional districts in the State.

28. Initially, the Independent Redistricting Commission stated that they would work to develop

fair, non-partisan leaning legislative and congressional districts. Secondly, and more

strongly, the Commission indicated they would respect and protect communities of interest.

29. From review of their draft plans, it is clear that the Commission has failed in both of these

regards.

2
https://www.census.gov/quickfacts/fact/table/detroitcitymichigan,mi/PST045217
3
Race and Ethnicity in the Tri-County Area: Selected Communities and School Districts; See also From a Child's
Perspective: Detroit Metropolitan Census 2000 Fact Sheets Series. Wayne State University. June 2002. Volume 2,
Issue 2. p. 1. Retrieved on November 10, 2013.
4
https://www.freep.com/story/news/politics/elections/2020/11/06/joe-biden-detroit-michigan-vote-election-
2020/6168971002/

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30. Two of the largest communities of interest in Michigan are the Black population and the

City of Detroit.

31. Although the Commission indicated they planned to protect communities of interest, they

produced a Senate Plan that divided Detroit into eight pieces.

32. Of those eight pieces, not one Senate District as a whole contained the City of Detroit, but

instead, sections of Detroit are apportioned to other, majority-White polities including:

Bloomfield Hills, Birmingham, Canton, Farmington, Madison Heights, New Baltimore,

Sterling Heights, and Clinton Township.

33. The redistricting plans of the Michigan Independent Redistricting Commission are
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AYAD LAW, P.L.L.C.

bipartisan gerrymandering which, if implemented, would unlawfully reduce the voting


645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

power of minority racial groups to elect the candidate of their choosing.

34. The reduction of majority-minority districts from the plans previously adopted in 2011 can

be plainly seen by the results of the redistricting on the representation of Black voters and

the citizens of City of Detroit.

Examples of Retrogression: 2011 to 2021

35. Congressional Plans

 2011 Plans contain 2 (two) majority Black wards

 2021 Plans contain 0 (zero) majority Black wards

36. State Senate Plans

 2011 Plans contain 5 (five) majority Black wards

 2021 Plans contain 0 (zero) majority Black wards

37. State House Plans

 2011 Plans contain 12 (twelve majority) Black wards

 2021 Plans contain 2 (two) majority Black wards

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Examples of Cracking: 2011-2021

38. City of Detroit

 Total population 2021 = 639,111

 Average Population of State Senate District 2021 = 265,193

39. Number of Majority Wards Possible in the City of Detroit

 Completely contained = 2.41

 Partially contained = 4.73

 Defendant’s plan has eight State Senate Districts occupying the City of Detroit

which dilutes the city’s voting power and potentially eliminates any State Senator
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from Detroit in 2023.


645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

COUNT I
Violation of Mich Const 1963, art 4, §6(13)(a) and (c):
Dilution of Minority Voting Power

40. Plaintiffs reallege the prior paragraphs as if restated fully hereunder.

41. The Michigan Constitution of 1963 provides:

(13) The commission shall abide by the following criteria in proposing and
adopting each plan, in order of priority:
(a) Districts shall be of equal population as mandated by the United States
constitution, and shall comply with the voting rights act [of 1965] and other
federal laws.

Mich Const 1963, art 4, §6(13)(a) (emphasis added).

42. The Voting Rights Act of 1965 holds, in pertinent part:

No voting qualification or prerequisite to voting or standard, practice, or


procedure shall be imposed or applied by any State or political subdivision
in a manner which results in a denial or abridgement of the right of any
citizen of the United States to vote on account of race or color…

52 USCA § 10301.

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43. In determining whether the Voting Rights Act statute has been violated, this Court follows

"the guidance of the United States Supreme Court, [as] stated in Thornburg v. Gingles, 478

U.S. 30, 43–46, 106 S.Ct. 2752, 2762–2764, 92 L.Ed.2d 25 (1986)…" In re Apportionment

of State Legislature-1992, 439 Mich 715, 735; 486 NW2d 639, 650 (1992).

44. In Thornburg v. Gingles, 478 U.S. 30, 43–46, 106 S.Ct. 2752, 2762–2764, 92 L.Ed.2d 25

(1986), Supreme Court of the United States has held that a successful Section 2 vote

dilution claim has two components. First, a plaintiff must satisfy three preconditions by

showing: (1) that the minority group is “sufficiently large and geographically compact to

constitute a majority in a single-member district”: (2) that the minority group is “politically
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AYAD LAW, P.L.L.C.

cohesive”: and (3) that bloc voting by other members of the electorate usually defeats the
645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

minority-preferred candidates. Satisfaction of these three preconditions is necessary but

not sufficient to establish liability. Second, “[i]f these three preconditions are met, the

district court must then examine a variety of other factors to determine whether, under the

totality of the circumstances, the challenged practice impairs the ability of the minority

voters to participate equally in the political process and to elect a representative of their

choice.” As stated in Gingles, 478 U.S. at 36-37, additional “objective factors” used in

determining the “totality of circumstances” surrounding an alleged violation of Section 2

of the Voting Rights Act include (but are not limited to) the extent to which the members

of the minority group bear the effects of discrimination in areas like education,

employment, and health, which hinder effective participation, is one measure.

45. (1) The Black citizens of the City of Detroit are a minority group that is “sufficiently large

and geographically compact to constitute a majority in a single-member district” as its

population is 77.7% Black as per the 2020 cencus.

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46. (2) The Black citizens of the City of Detroit are “politically cohesive” as is shown by their

voting record where Detroit Black persons account for 79.1% of the total population of

Detroit.5 Biden won the city of Detroit with 94% of the vote while Trump received 5%. 6

Yet statewide in Michigan voter turnout was 71% and Biden defeated Trump by merely

50.6% to 47.9%, meaning that it was the Detroit Black community who, voting as a

cohesive group, won the Presidential election for President Joseph Biden in this State and,

potentially, the Country.

47. (3) Bloc voting by other members of the electorate usually defeats the minority-preferred

candidates: Until the 1954 election of Charles Diggs in the old 15th District (13th today)
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AYAD LAW, P.L.L.C.

followed by the election of John Conyers 10 years later in 1964 in the old 1st District (14th
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DETROIT, MICHIGAN 48226

today) Detroit’s majority-minority community could not elect a Congressional candidate

of their choice.

48. The Black citizens of the City of Detroit bear the effects of discrimination in the area of

education:

a. In the city of Detroit the majority of the residents in the suburb area are

predominantly White, while in the actual city majority of the residents are Black. 7

b. As of the mid-2000's, school funding per pupil in Wayne County (where Detroit is

located) was approximately $930.33, the lowest in the State. The second highest

was $1,239.47 per pupil, in Macomb County, almost 50% more than that of Wayne

County and far below the average for Southeastern Michigan of $1,807.17. 8

5
https://www.census.gov/quickfacts/fact/table/detroitcitymichigan,mi/PST045217
6
https://www.freep.com/story/news/politics/elections/2020/11/06/joe-biden-detroit-michigan-vote-election-
2020/6168971002/
7
Checkoway, Barry; Lipa, Todd; Vivyan, Erika; Zurvalec, Sue (2017). "Engaging Suburban Students in Dialogues
on Diversity in a Segregated Metropolitan Area". Education and Urban Society. Sage Journals. 49 (4): 388–402.
8
D., Rollandini, Mark. Michigan intermediate school districts: funding and resource allocation. p. 22.

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c. Detroit public schools have high illiteracy rates and low academic performance

compared to cities across the United States, with Detroit "eighth graders scor[ing

the] lowest in math and reading in the nation."9

d. According to the National Institute for Literacy, 47% (200,000) of adults in Detroit

are functionally illiterate, and half of the 200,000 adults do not have a high school

diploma or GED, showing that the lack of these skills learned in an academic setting

is generationally embedded into different groups of society.

49. The Black citizens of the City of Detroit bear the effects of discrimination in the area of

employment:
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AYAD LAW, P.L.L.C.

a. Detroiters have a lower employment rate compared to others living in Wayne


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DETROIT, MICHIGAN 48226

County and those in neighboring counties such as Macomb and Oakland. In July

2020, unemployment in Detroit reached nearly 40 percent. 10 This is much higher

than the national unemployment average of even The Great Depression nearly a

century ago.11

b. As of 2016, Detroit's poverty rate was 35.7%, with a median household income of

just over $28,000.12

50. The Black citizens of the City of Detroit bear the effects of discrimination in the area of

health:

9
Rosenbaum, Mark (2018-01-30), The Miseducation of America, Center for Political Studies (CPS).
10
Wileden, Lydia. 2020. “emplyment Dynamics in Detroit During the COVID-19 Pandemic.” Detroit Metro Area
Communities Study, University of Michigan. https:// detroitsurvey.umich.edu/wp-content/uploads/2020/08/
Unemployment-August-2020.pdf.
11
Rashawn Ray, Jane Fran Morgan, Lydia Wileden, Samantha Elizondo, and Destiny Wiley-Yancy; Examining and
Addressing COVID-19 Racial Disparities in Detroit; The Brookings Institution, p. 14.
12
Williams, Corey (14 September 2017). "Census Figures Show Drop in Detroit Poverty Rate". U.S. News.

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a. Because of the legacies of underinvestment, redlining, jobs without benefits, poor

or nonexistent and culturally incompetent health care, Black residents are less likely

to be able to transcend the challenges presented by COVID-19 and are more likely

to contract and die from the virus.13

b. In Detroit, Black people represent a comparable over 75 percent of known COVID-

19 diagnoses by race, yet account for a disproportionate nearly 90 percent of deaths.

Id.

51. Therefore, according to the analysis handed down in Thornburg v. Gingles, 478 U.S. 30,

43–46, 106 S.Ct. 2752, 2762–2764, 92 L.Ed.2d 25 (1986), the redistricting Plans approved
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by Defendant violate the Voting Rights Act of 1965 (52 USCA § 10301) by implementing
645 Griswold St., Ste. 2202
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impermissible dilution of the Black vote in Michigan. As the Plans violate the Voting

Rights Act, they also violate the Michigan Constitution at article 4, §6(13)(a) and (c).

COUNT II
Violation of Mich Const 1963, art 4, §6(13)(a) and (c):
Prohibited Retrogression of Minority Voting Power

52. Plaintiffs reallege the prior paragraphs as if restated fully hereunder.

53. "§ 5 of the [Voting Rights] Act is not necessarily subject to a dilution challenge under § 2.

The sections differ in structure, purpose, and application; and in contrast to § 2 cases, a

baseline for comparison under § 5 exists by definition: A proposed voting practice is

measured against the existing practice to determine whether retrogression would result

from the proposed change." Holder v Hall, 512 U.S. 874, 875, 114 S.Ct. 2581, 2583.

13
Rashawn Ray, Jane Fran Morgan, Lydia Wileden, Samantha Elizondo, and Destiny Wiley-Yancy; Examining and
Addressing COVID-19 Racial Disparities in Detroit; The Brookings Institution, p. 1.

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54. Under the new redistricting Congressional Plans the number of majority Black wards

would be reduced from two to zero; under the State Senate Plans, from five to zero; and

under the State House Plans, from 12 to 2.

55. Therefore, Defendant's proposed redistricting Plans constitute an unconstitutional,

unlawful, and intolerable retrogression of the political achievement of Black persons in

Detroit, and so violate Section 5 of the Voting Rights Act of 1965 (52 USCA § 10304(b,

d)) and, necessarily, the Michigan Constitution at article 4, § 6(13)(a), (c).

COUNT III
Declaratory Action

56. Plaintiffs reallege the prior paragraphs as if restated fully hereunder.


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AYAD LAW, P.L.L.C.
645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

57. The Court has the power to enter declaratory judgments. MCR 2.605(A)(1).

58. A case of actual controversy exists between these parties as Plaintiffs will imminently have

their rights under the Michigan Constitution, the United States Constitution, and federal

law (the Voting Rights Act of 1965) violated and be effectively completely

disenfranchised.

59. Guidance is needed by the Court to assist the parties in their conduct going forwards, so

that Plaintiffs and the entire Black population of Southeastern Detroit does not suffer the

egregious and inexcusable injury of being racially discriminated against, disenfranchised,

and having their legal, political, and civil rights eroded in one fell swoop.

60. The case in controversy is within the jurisdiction of this Court as, were the rights at issue

violated, this Court would have original jurisdiction to hear causes of action arising out of

those violations pursuant to Mich Const 1963, art 4, §6(19).

61. Specifically, Plaintiff requests a declaration from this Court that Defendant's proposed

Michigan's Congressional, State Senate, and State House district voter districts Plans are

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unconstitutional and unlawful as they do not comport with the requirements of the Voting

Rights Act of 1965 and the Michigan Constitution of 1963, article 4, §6(13)(a)-(c).

CONCLUSION AND RELIEF REQUESTED

The new voting district maps drawn by the Commission will thwart the Black Civil Rights

Movement that this nation is famous for; that this nation is proud of. Should this Court not stop

the Defendant from implementing their Plans, the Black voters of Michigan will be cast backwards

in time to the days before Civil Rights heroes like Martin Luther King, Jr. and Rosa Parks led the

fight for the representation that Detroiter's currently have. The community of interest that is the

Detroit Black community, will go from one that can unite to become powerful enough to win the
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United States presidency for their chosen candidate to one that cannot even elect state congress
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persons and senators; no matter what their voter turnout.

Under the Voting Rights Act of 1965, and therefore, the Michigan Constitution, it does not

matter what the intentions of Defendant's members were, only what the effects of their redistricting

will be. The effects are clear: By breaking the majority-Black City of Detroit into eight voter

districts from its previous two voter districts, it will dilute the vote of the Black community in

Southeastern Michigan into meaninglessness. By reducing the ability of Black voters to be

represented in this state and nationally. Defendant's Plan for the US Congressional districts, the

number of majority Black wards would be reduced from two to zero; under the State Senate Plans,

from five to zero; and under the State House Plans, from twelve to two. That is a total of 19

majority-minority wards reduced to just two.

The Commission was supposedly created to assure that the Voter Rights Act of 1965 was

not violated. Unfortunately, that is exactly what is happening here. As the Voter Rights Act assures

that majority-minority districts are not to be diluted in newly redrawn districts so that minority

communities cannot elect their candidates of choice. This map falls far short of such mandates

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under the Voter Rights Act and, if this Court does not act decisively to curb Defendant's ill-made

Plans, then Black Detroiters, and the Black community everywhere, will suffer an egregious and

despicable injury. As the late Martin Luther King, Jr. one said: "Injustice anywhere is a threat to

justice everywhere." This Honorable Court should act swiftly to save the State of Michigan from

the shame and embarrassment that will be associated with Defendant's redistricting Plans.

WHEREFORE, Plaintiff requests that this Honorable Court enter judgement in their favor

against Defendant and issue an order containing the following relief:

a) Declaring that Defendant's currently proposed redistricting plans violate the Michigan

Constitution of 1963, art 4, §6(13)(a) and (c) and the Voting Rights Act of 1965 by
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impermissibly diluting the City of Detroit and majority Black votes of Detroiters;
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b) Declaring that Defendant's currently proposed redistricting plans violate the Michigan

Constitution of 1963, art 4, §6(13)(a) and (c) and the Voting Rights Act of 1965 by

impermissibly retrogressing the voting power of the Black community in the City of

Detroit;

c) Ordering that Defendant be required to redraw their redistricting plans in accordance

with the Michigan Constitution of 1963, art 4, §6(13)(a) and (c) and the Voting Rights

Act of 1965 and the order of this Court;

d) Awarding reasonable attorneys fees; and

e) Any and all such other relief that this Court deems just and equitable including any

tolling of limitations periods necessary to accomplish justice.

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Respectfully submitted;

AYAD LAW, PLLC

/s/Nabih H. Ayad
Nabih H. Ayad (P59518)
William D. Savage (P82146)
Attorneys for Plaintiff
645 Griswold St., Ste 2202
Detroit, MI 48226
P: 313.983.4600
F: 313.983.4665
Dated: January 3, 2022 [email protected]
P: (313) 983-4600 | F: (313) 983-4665
AYAD LAW, P.L.L.C.
645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

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VERIFICATION

I declare under the penalties of perjury that this Complaint has been examined by me and

that its contents are true to the best of my information, knowledge, and belief.

Executed on: ____________________________

Signed: ____________________________
Plaintiff
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AYAD LAW, P.L.L.C.
645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

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CERTIFICATE OF SERVICE

I hereby certify that on this date I filed the foregoing paper and any attachments with the

Clerk of Courts for the Michigan Supreme Court using the MiFile electronic filing system.

Respectfully submitted;

AYAD LAW, PLLC

/s/Nabih H. Ayad
Nabih H. Ayad (P59518)
William D. Savage (P82146)
Attorneys for Plaintiff
645 Griswold St., Ste 2202
Detroit, MI 48226
P: (313) 983-4600 | F: (313) 983-4665
AYAD LAW, P.L.L.C.

P: 313.983.4600
645 Griswold St., Ste. 2202
DETROIT, MICHIGAN 48226

F: 313.983.4665
Dated: January 3, 2022 [email protected]

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