Court filing, Complaint (for reapportionment), August 18, 1964

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 ; MELVIN D. CLOSE. JR. ATTORNEY ANO COUNSELOR AT LAW IM-A NORTH THIRD ST. | LAS VECAS. NEVADA 89101 TELEPHONE 384-1532 TELEPHONE 384-6901 I CASE NO . IN TH E UNITED ST ATES DISTRICT C OURT FO R T HE DIS TRICT OF NEVADA FLORA D UNGAN, also known as FLORA O NCKEN and C. W. WOODBUI M. D. Plaint iffs vs GRANT S AWYER, Governor of the State of Nevada, JOHN K OONTZ, Secretary of the State of Nevada, PAUL L AXALT, Lieutenant Governor of the State of Nevada, MICHAEL MIRABELLI, Treasurer of the State of Nevada, and JOHN D OES I through XX, Defendants C O M P L A I N T COMES NOW the above named Plaint iffs, and for cause of act ion against the above named Defendants allege: FIRST CA USE OF A CTION I The jurisdict ion of this Court and the Plaint iffs' right to bring this act ion are found under the Civi l Rights Act , 42 USC Se c. 1983 and 1988. This Court has addi tional jurisdict ion under 28 USC, Sec. 1343. Relief hereunder is further sought pursuant to the Federal Declaratory Judgment Act, 28 USC Se c. 2201 and 2202. II As appears more ful ly below, the Plaint iffs herein seek rel ief con?sist ing of interlocutory or permanent injunct ions restraining the endorsement, operation or execution of the Consti tut ion and statutes of Nevada by restraining the act ions of State officers in the enforcement or execution of such statutes, and by d eclaring Article IV, Sect ion 5, of the Nevada S tate Consti tut ion to be unconsti tut ional as wel l as Nevada Revised Statute 218.050 - 218.080. III The individual Plaint iffs herein are ci tizens, taxpayers and electors 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 MELVIN D. CLOSE. JR. ATTORNEY AND COUNSELOR AT LAW 114-A NORTH THIRD ST. LAS VEGAS. NEVADA 89101 TELEPHONE 384-1552 TELEPHONE 384-6901 of the United States and of the State of Nevada, and as qual i fied voters in said State, are ent i t led to vote for members of the Senate and the Assembly of the State of Nevada. That as appears in the following l ist , each of the Plaint iffs reside at the address shown below, and are taxpayers and qual ified voters of the below indicated count ies: PLAINTIFF ADDRESS Flora Dungan, also known as Flora Oncken ' G. W. Woodbury 1904 Cochran Las Vegas 430 South Seventh Las Vegas COUNTY Clark Clark The aforementioned Plaint iffs joint ly and several ly bring this act ion on thei r own behal f and on behal f of al l other persons , ci tizens, taxpayers and voters in the State of Nevada who a re simi larly si tuated. IV The Defendants are al l ci tizens of the United States and of the State of Nevada an d reside wi thin said State. That the Defendant, GRANT S AWYER, i s the duly elected, qual ified and act ing Governor of the State of Nevada, with his offices at the Capi tal , Carson Ci ty, in said state. That the Defendant, PAUL LA XALT, is the duly elected, qual i fied and act ing Lieutenant Governor of the State of Nevada, with his offices at the Capi tal Carson Ci ty, in said state, and as such is the ex-officio president of the Nevada State Senate. That the Defendant JOHN K0 0NTZ is the duly elected, qual ified and act ing Secretary of State of the State of Nevada, with his offices at the Capi tal , Carson Ci ty, in said state. That the Defendant, MICHAEL M IRABELLI, is the duly elected qual i fied and act ing Treasurer of the State of Nevada, wi th his offices at the Capi tal , Carson Ci ty, in said state. That this act ion is brought against the Governor, Lieutenant Governor, Secretary of State and Treasurer in thei r respect ive official capaci ties, includ?ing any successors to such official posi tions. There is a common q uestion of law involved, that is, the const itut ional ity of the State Consti tut ional and Statutory - 2 - 1 2 2 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 ' 31 32 j E. JR. 3 AW D ST. ! j 1 552 provisions relat ing to legislat ive appor t ionment. V That the Plaint iffs are denied the right to due process and the equal ,protection of the laws as guaranteed by the Fourteenth Amendment to the Consti tut?ion of the United States. They bring this act ion on thei r own behal f and on behal : of al l ci tizens, taxpayers and qual i fied voters of the respect ive count ies of the State of Nevada, and further on behal f of al l voters of the State of Nevada who are simi larly si tuated, for a declarat ion of thei r rights and a declarat ion of the inval idi ty of those sect ions of the Consti tut ion of the State of Nevada and the statutes implementing said sections which apportion the elect ion of Senators and Assemblymen in the State of Nevada, and for such declaratory and injunctive rel ief as may be proper to assure them and al l others simi larly si tuate! due process and equal protection of the laws which are now and have been for many years denied them by the Defendants and thei r Predecessors in office who have complied wi th certain provisions of the Consti tut ion of the State of Nevada and statutes implementing said provisions, which are violat ive of the Consti tution of the United States, al l of which are being particularly set forth hereinafter . VI That the Consti tut ion of the State of Nevada provides for apportion?ment for elect ion of the Senate and Assembly under Article IV, Section 5 thereof , and that in implementation thereof the legislature at various times has enacted apportionment laws present ly consisting of Sect ions 218.050 - 218.080, Nevada Revised Statutes. Said Consti tut ion and laws are binding upon the Defendants herein in connection with the performance by them of thei r official dut ies relat?ing to apportionment and elect ion procedures in the State of Nevada. Said Defend?ants have in the past complied and i t must be preseumed that they wi l l continue to comply, wi th the said State Consti tut ional provisions and laws thereunder unt i l such times as the provisions shal l be declared by competent authority to be inval id. VII That the provisions of the Consti tut ion of the State of Nevada, Articl< IV, Section 5 thereof , violates the Fourteenth Amendment of the Const itut ion of -3- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 MELVIN D. CLOSE. JR. ATTORNEY AND COUNSELOR AT LAW 114-A NORTH THIRD ST. LAS VESAS. NEVADA 89101 TELEPHONE 384-1552 TELEPHONE 384-6901 the United States because the apportionment formula contained therein resul ts, and must necessarily result , when a ppl ied to the population figures of the State of Nevada a s establ ished by t l : 196 0 census in a grossly unfai r weighting of both houses of the State Legislatui : in favor of the lesser populated rural areas of the state. Said Constitut ion. -cvisions and Statutory laws as applied to the present facts of the State of a and the 1960 census, establ ishes an arbi trary and capricious apportionment c : i:resentat ives in the Senate and Assembly without reference to any logical or reasonable formula whatever, resul ting in a gross under representat ion in both houses of the larger urban areas and in gross over-repre?sentat ion in both houses of the sparsely populated areas. There, is attached here?to marked Exhibit "A", a table of the pert inent information as to populat ion and apportionment under the various acts and the Consti tut ion of the State of Nevada, which is made a par t hereof as i f set forth in ful l . VIII The legislature of. the State of Nevada has enacted Nevada Revised Statute 218.050 on apportionment laws relat ing to the Senate of the State of Nevad and pursuant to the Consti tut 1 and Statutory provisions one Senator is elected from each county. As a resul t this appor t ionment, based on the 1960 census, Senators elected from count ies containing 7.96 percent of the population of Nevada control 52.94 percent of the Senate vote, and Senators from count ies represent ing 25.77 percent of the population of Nevada control 88.24 per cent of the Senate votes , and there is an extreme between one Senator for 127.016 people in Clark County and one Senator for 568 people in Storey County. Thus as can be seen from Exhibit 'A" a t tached hereto, 223.62 Clark County voters have the same representa?t ion in the Senate as does one voter from Storey County, which apportionment is arbi trary and capricious without any reference to any logical or reasonable formuls whatever and is in violat ion of the Fourteenth Amendment. IX Pursuant to the Consti tut ional provisions above ci ted, the legislature enacted Sect ion 218.050 of the Nevada Revised Statutes. Based upon the 1960 census Assemblymen elected from count ies containing 39.8 per cent of the populat ion con- 3j |Cr01 51' 4 pe rc enC of the Asserably and there are extremes in representat ion where - 4 - orl 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 311 32 E. JR. 3 i AW 0 ST. i 5 52 ! >901 is elected by 568 people in S aey County and one is elected by 10,535 people in Clark County. Thus as can be seen from Exhibi t "A" attached hereto, 18.64 Clark County voters have the same representat ion in the Assembly as does one voter from Storey County. The apportionment is arbi trary and capricious arid without refer?ence to any logical or reasonable formula whatever and is in violat ion of the Fourteenth Amendment. X Pursuant to the Consti tut ional provision above ci ted, the legis?lature enacted Section 218.06(*of Nevada R evised Statutes. This statute apport?ioned Clark County into four ( V) districts as of 1960. (This Section has sub- ? sequently been amended to ere :e District 5 which comprises North Las Vegas. District 5 is represented by o ic Assemblyman and District 2 was reduced by one (1) Assemblyman to 8) Within Clark County the following inequi ties exist based on the 1960 census: DISTRICT 1960 CENSUS NO. ASSEMBLYMEN EACH R EPRESENT N?. 1 4,400 1 4,400 No. 2 106,971 9 11,885 No. 3 3,120 1 3,120 No- 4 ^,525 _J 12,525 127,016 12 The foregoing i llustrat ion; of the malapportionment of the Senate and the Assembly of the State of Nevada exhibi t the gross over-representat ion of the sparsely set tled rural count ies and the gross under-representat ion of the more populous count ies . The appl icat ion of the 1950 formula based on the 1960 census and the fai lure of the legislature of the State of Nevada to equitably apportion the elect ion of Senators and Assemblymen resul ts in the individual Plaint iffs' votes and the votes of al l other parties simi larly si tuated suffering a debase?ment and a fract ional izat ion by virtue of an arbi trary, obsolete and unconsti tut?ional apportionment of both houses of the legislature, to the denial of said in?dividual Plaint iffs and al l of those simi larly si tuated of due process of law and equal protect ion of the laws . -5- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 MELVIN D. CLOSE. JR. ! ATTORNEY AND COUNSELOR AT LAW IM-A NORTH THIRD ST. : J LAS VEGAS. NEVADA 89101 TELEPHONE 384-1552 I TELEPHONE 384-6SO! XI That the malapportionment of the Senate and the Assembly of the State of Nevada under the 1960 censii ; is a purposeful and systematic plan embodied in the Consti tut ion of the State >f Nevada and Sect ion 218.050 - 218.080 of the ? Nevada Revised Statutes, to dj criminate against certain geographic areas and classes of persons and to den) their, t he equal protect ion of the laws guaranteed to al l people of Nevada by the Federal Const itut ion. That the ent ire purposeful and systematic const itut ional and stat?utory provisions are to l imi t the representat ion of the populous count ies and to exaggerate the representat ion of the sparsely set t led count ies, to the denial of the rights of Plaint iffs and those simi larly si tuated as guaranteed by the Federal Consti tut ion. That i t is apparent as a resul t , that the Plaint iffs and others simi larly si tuated in the State of Nevada a re governed by a legislature, nei ther house of which is a body representat ive of the people of the State and that such control by succeeding rural legislators represent ing a minority of the people of the State of Nevada confl icts wi th the concept of government by consent of the governed and is contrary to the prevai ling philosophy of government embodied in the Tenth Amendment of the Consti tut ion of the United States and recognized by al l Anglo-Saxon jurisdict ions whereby the legislature has power to make laws only because i t has the power and the duty to represent the people, and recent decis?ions of the United States Supreme Court . XII The Defendants or thei r successors in office unless prevented by this Court must perform the dut ies as they and thei r predecessors in office have performed those dut ies under the challenged Consti tut ional provisions and statutes of the State of Nevada; and the rights of these Plaint iffs and other simi larly si tuated ci tizens, taxpayers and voters of the State of Nevada can only be pro?tected by a decree of this Court declaring Art icle IV, Section 5 of the Nevada Consti tut ion and apportionment laws Sections 218.050 - 218.080 Nevada Revised Statutes, and thei r predecessors, to be unconsti tut ional and by enjoining the Defendants from performing any acts or dut ies in compliance wi th these unconst?i tut ional provisions . -6- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 211 22 23 24 25 26 27 28 29 30 31 32 E. JR. 5 AW D ST. ; 1 S52 XIII The Plaint iffs have no adequate remedy other than the judicial rel ief sought herein. Unti l such time as Art icle IV, Sect ion 5 of the Nevada C onsti tut io has been declared in whole or in par t inval id, Defendants wi l l be bound thereby and are not free to exercise any discret ion to eliminate the deprivat ion suffered by Plaint iffs. Only judicial relief can remedy this condi tion for the following reasons: (a) The legislature is control led and dominated by persons elected by a minority of the ci tizens as hereinabove noted who may b e duly expected to preserve the status quo which perpetuates thei r domination. (b) The past action and inact ion of the Nevada S tate legislature is proof that Plaint iffs' only remedy l ies wi th this Honorable Court. SECOND C AUSE OF A CTION I The Plaint iffs repeat each and every al legat ion contained in Paragraphs I through XIII of the First Cause of Action wi th the same force and effect as i f set forth herein. II That the Nevada S tate Legislature, as appor t ioned in the Senate and the Assembly as heretofore set out , control led by Consti tut ion and Statute as heretofore noted, as a resul t of such appor t ionment, has consciously and purpose?ful ly discriminated against the Plaint iffs and others simi larly si tuated in such manner as to deprive such persons of due process of law and equal protect ion of the laws . In part icular , said aforesaid malapportionment of said legislature has for a number of years increasingly unjustly discriminated against the in?creasingly large segments of the population of Nevada in the urban areas and thei r urban fringes of the populous count ies . That such dispari ty between pop?ulat ion, as well as the over-representat ion of the same count ies in the State Legislature, amply i l lustrates the necessary and resul ting bias of such count ies and representat ives thereof in the control of the Legislature in enacting statute; of the State of Nevada to the detriment , discrimination and deprivation of due process of law and equal protection of law of the Plaint iffs and al l persons -7- ] I ; A t e ? S 1C 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 E. JR. 3 AW D ST. 1 552 simi larly si tuated, al l in conl raveat ion of the Fourteenth Amendment. T1 i CVUSE O F AC TION I The Plaint iffs re . L each and every al legat ion contained in Para?graphs I through XIII of the First Cause of act ion wi th the same force and effect as i f set forth herein. II That present malapportionment of the Senate and the Assembly of Nevada is the end product of a long establ ished purposeful and systematic plan embodied in the Consti tut ion oi the State and implemented by progressive statutory steps to discriminate against certain geographic areas and classes of persons ind to deny to them the equal Protect ion of the laws, guaranteed to al l people >f Nevada by the Federal Consti tut ion. Beginning in 1915 and continuing to date, >ection 13, Art icle I of the N /ada State Consti tut ion which provides that "Re- >resentation shal l be appor t ioned according to populat ion" has been intent ion-t lly and wi lful ly violated in both Senate and Assembly appor t ionment . Sect ion >, Article IV of the Nevada S tate Consti tut ion, as amended, is diametrical ly >pposed to the mandate found in Section 13, Art icle I, and is unconsti tut ional , 'hat during said period population was shif t ing to a few populous count ies. That >y t his purposeful and systematic plan embodied in the Consti tut ion and imple-lented by the statutes aforesaid, aggressive disenfranchisement of persons l iving n the populous growing areas of the state, without decreasing the vot ing rights 'f the rural decl ining areas of the state, has been accomplished, to the denial f the Plaint iffs and those simi larly si tuated of the rights guaranteed by the ederal Const itut ion. When al l of the inequi ties and dispari t ies resul ting from ha Consti tut ional and Statutory formula, the apportionment of the Senate and he apportionment of the Assembly, are taken together , i t is apparent that Plain-iffs and other simi larly si tuated in the State of Nevada are governed by a legis-ature nei ther house of which is a body representat ive of the people of the state; hatever just ificat ion there may be for some greater weight to be givm to geo-raphic representat ion in one house or the other of a bicameral legislature, i t s apparent that the gross distortions of apportionment of both houses of the - 8- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Nevada L egislature, nei ther in whole nor in part, can be just ified thereby. Such malapportionment Sanctioned by the State Consti tut ion and systematically perpet-uated by succeeding rural ly control led legislators conflicts with the concept of government by consent of^thc governed and is contrary to the prevai ling phi l?osophy of government embodied n the Tenth Amendment to the Consti tut ion of the United States, and recognized by al l Anglo-Saxon jurisdict ions whereby the legis?lature has power to make laws only because i t has the power and the duty to re?present the people. V/IIEREFORE, based on the aforesaid causes of act ion, the Plaint iffs respectful ly plead that : 1. This Court take jurisdict ion of this matter ; that a special three judge Court be cal led to hear and determine this cause as provided by law in 23 USC Se c. 2201 in the premises , to wi t : (a) That Art icle IV, Section 5, of the Consti tution of the State of Nevada h as deprived and continues to deprive the Plaint iffs of l iberty and property without due process of law and deprives Plaint iffs of equal protection of the laws in violat ion of the Fourteenth Amendment of the Consti tut ion of the United States . (b) That the apportionment law of 1950, Sect ion 218.050 - 218.080, Nevada R evised Statutes, as applied to the 1960 census and under the Const i tut ion, provisions of Art icle IV, Sect ion 5, has deprived and continues to deprive Plain?t iffs or equal protect ion of the laws in violat ion of the Fourteenth Amendment to the Consti tution of the United States. (c) that there has been a long establ ished purposeful and systematic plan embodied in the Consti tut ion of the State of Nevada, Art icle IV, Sect ion 5, whereby act ive and progressive steps have been taken and which discriminate against certain geographic areas and classes of persons , depriving and continuing to deprive Plaint iffs and al l those simi larly si tuated of l iberty and property without due process of law and simi larly deprives said persons of equal protect?ion of the laws in violat ion of the Fourteenth Amendment of the Consti tut ion of the United States. 32 MELVIN D. CLOSE. JR. ATTORNEY AND COUNSELOR AT LAW II4-A NORTH THIRO ST. LAS VEGAS. NEVADA 89101 TELEPHONE 384-1552 TELEPHONE 384-6901 i (d) That any apportionment law enacted must elect both houses -9- 1 2 3 4 5 6 7 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 | 24 25 26 27 28 29 30 31 32 MEL.VIN D. CLOSE. JR. ATTORNEY AND COUNSELOR AT LAW II4-A NORTH THIRD ST. LAS VEGAS. NEVADA 39101 TELEPHONE 384-1552 TELEPHONE 384-6901 wholly on the basis of populat ion. 2. Plaint iffs further pray that after hearing this act ion the Court grant further rel ief in accordance with 28 USC, Sec. 2202 as fol lows: (a) To not ify the Legislature of the State of Nevada convening in January 1965, that this Court shal l retain jurisdict ion of the cause during the term of such Legislature to determine at the end thereof what new ap portionment system has been devised to meet the requirements of the Fourteenth Amendment or the Consti tution of the United States and the val id provisions of the Con?st i tut ion of the State of Nevada, and for further hearings herein as to determin?at ion of the val idi ty of any new apportionment law as may b e enacted or determin- IX nat ion of a proper apportionment system in absence of any act ion by the Legislature (b) To restrain the Defendant, GRANT S AWYER, Governor of the State of Nevada, or his successor , from cal ling other than a properly apportioned Legis?lature into session after April , 1965, and from applying and implementing any and al l statutes of the State of Nevada in such manner as to deprive Plaint iffs du process and equal protection of the laws as guaranteed by the Consti tut ion of the United S tates . (c) To restrain the Defendant, MICHAEL M IRABELLI, Treasurer of the State of Nevada, or his succes: >rs, from paying any warrants presented to him for compensation due any legis i tor after April 1965, unless said legislature has been reapportioned or al l :j.d legislators have been elected on an at-large basis. (d) To restrain t . Defendant, JOHN K0 0NTZ, from promulgating any rules or regulat ions pertaining to the primary or general elect ion for Senators or Assemblymen a fter November 3, 1964, unless' said Legislators have properly apport?ioned themselves or run for elect ion on an at-large basis throughout the State of Nevada. 3. That, i f for any reason the Nevada S tate Legislature has not reap?por t ioned i tself by the next elect ion for Senators and Assemblymen, after the Cour has declared Art icle IV, Sect ior 5, and al l statutory -laws based thereon to be voi, and unconsti tut ional, that al l t imbers of the Senate and Assembly run for elect ion on an at-large basis throughout the State of Nevada. 9 -10- 1 2 2 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 j 32 : I. JR. 5 AW , OST. | ' 652 4. Plaint iffs further pray that this Court : (a) Should retain jurisdict ion of this cause unt i l such time as the Legislature of the State, freed from the fet ters imposed by Consti tut ional pro?visions invalidated by this Court , and required to provide proper apportionment in place of apportionment acts heretofore enacted being invalidated by this Court, provides by enactment in the 1965 Legislature such apportionment of the State Legislature as wi l l insure to the urban voters of the populous count ies the rights guaranteed them by the Consti tut ion of the United States. (b) Should grant such other and further relief as to this Court may seem just and proper. DATED t his 18th day of August, 1964. KELVIN D. CLOSE, Attorney for Plaint iffs 114-A North Third Street Las Vegas, Nevada STATE OF N EVADA) ss COUNTY O F CL ARK) FLORA D UNGAN, also known as FLORA ON CKEN, being first duly sworn, according to law, on oath deposes and says: That she is one of che Plaint iffs in the above ent i t led act ion; that she has read the foregoing Complaint and knows the contents thereof , and that for hersel f and on behal f of the other Plaint iff she al leges that the same is true of her own knowledge, except as to any matters therein stated on information and bel ief, and as to those matters^ she bel ieves i t to be true. FLORA D UNGAN Subscribed and sworn to before ne this /S/ / ( day of August, 1964 .-/k?JL<L ''Sr? . , ,/y NOTARY P UBLIC in and ^or/said County and S tate. 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