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Case Name Davidson v. City of Cranston, Rhode Island VR-RI-0022
Docket / Court 1:14-cv-00091-L-LDA ( D.R.I. )
State/Territory Rhode Island
Case Type(s) Criminal Justice (Other)
Election/Voting Rights
Attorney Organization ACLU Chapters (any)
Case Summary
On February 14, 2014, the ACLU of Rhode Island and several citizens of the City of Cranston filed this lawsuit in the U.S. District Court for the District of Rhode Island. The plaintiffs sued the City of Cranston under 42 U.S.C. § 1983. The plaintiffs, represented by the Prison Policy Initiative, ... read more >
On February 14, 2014, the ACLU of Rhode Island and several citizens of the City of Cranston filed this lawsuit in the U.S. District Court for the District of Rhode Island. The plaintiffs sued the City of Cranston under 42 U.S.C. § 1983. The plaintiffs, represented by the Prison Policy Initiative, the ACLU, and private counsel, asked the court for declaratory and injunctive relief. The plaintiffs claim that the 2012 Redistricting Plan violated the rights of the plaintiffs to equal representation under the Fourteenth Amendment of the Constitution. Specifically, the plaintiffs claim that the inclusion of the prison population of Adult Correctional Institutions (ACI), located in Ward 6, inflated the actual voting population of ward 6. As a result, every three citizens of Ward 6 represent the same voting power as four citizens of the other five wards.

On March 13, 2014, the defendant filed a motion to dismiss. On September 8, 2014, Judge Ronald R. Lagueux denied the motion, holding that the court could not say that the 2012 Redistricting Plan was constitutional as a matter of law. 42 F.Supp. 3d 325 (D.R.I. 2014). The court scheduled discovery for the next nine months.

On July 9, 2015, the defendants filed a motion for summary judgment. On August 6, 2016, a cross motion for summary judgment was filed by the plaintiffs.

On May 24, 2016, Judge Lagueux granted plaintiffs’ summary judgment and denied defendants'. The court entered declaratory judgment for the plaintiffs and enjoined the defendants from holding any new elections under the current 2012 Redistricting Plan. Furthermore, the defendants were required to come up with a new redistricting plan within 30 days. Judge Lagueux determined that while districts are generally divided according to equal populations, the prison inmates at ACI were not engaged in the civil process like other non-voters. Therefore, to include them in the total population of Ward 6 would an unconstitutional dilution of Ward’s 1, 2, 3, 4 and 5’s voting power.

On May 31, 2016, the defendants filed a motion to appeal. On September 21, 2016, Judge Sandra Lea Lynch of the First Circuit Court of Appeals entered judgment in favor of the defendants. Judge Lynch held, following the Supreme Court’s decision in Evenwel v. Abbott, that in the absence of discriminatory intent, the courts should defer to local election authorities and the political process.

Brent Winslow - 09/28/2016


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Issues and Causes of Action
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Issues
Constitutional Clause
Equal Protection
Defendant-type
Jurisdiction-wide
General
Voting
Plaintiff Type
Non-profit NON-religious organization
Private Plaintiff
Voting
Redistricting/district composition
Vote dilution
Causes of Action 42 U.S.C. § 1983
Defendant(s) City of Cranston, Rhode Island
Plaintiff Description Four individuals and the ACLU chapter of Rhode Island
Indexed Lawyer Organizations ACLU Chapters (any)
Class action status sought No
Class action status granted No
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Declaratory Judgment
Injunction / Injunctive-like Settlement
Source of Relief Litigation
Form of Settlement None on record
Order Duration 2016 - 2016
Case Closing Year n/a
Case Ongoing Yes
Docket(s)
1:14−cv−00091−L−LDA (D.R.I.) 09/26/2016
VR-RI-0022-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Complaint 02/19/2014
VR-RI-0022-0001.pdf | Detail
Document Source: Bloomberg Law
Memorandum and Decision [Motion to Dismiss] 09/18/2014 (42 F.Supp.3d 325) (D.R.I.)
VR-RI-0022-0003.pdf | WESTLAW| LEXIS | Detail
Document Source: Bloomberg Law
Memorandum and Order [Summary Judgment] 05/24/2016 (2016 WL 3008194 / 2016 U.S.Dist.LEXIS 67674) (D.R.I.)
VR-RI-0022-0002.pdf | WESTLAW| LEXIS | Detail
Document Source: Bloomberg Law
Judges Lagueux, Ronald Rene (D.R.I.)
VR-RI-0022-0002 | VR-RI-0022-0003 | VR-RI-0022-9000
Monitors/Masters None on record
Plaintiff's Lawyers Labinger, Lynette J (Rhode Island)
VR-RI-0022-0001 | VR-RI-0022-9000
Lioz, Adam (District of Columbia)
VR-RI-0022-0001 | VR-RI-0022-9000
Wright, Brenda (Massachusetts)
VR-RI-0022-0001 | VR-RI-0022-9000
Young, Sean J (New York)
VR-RI-0022-0001 | VR-RI-0022-9000
Defendant's Lawyers Benoit, Normand G. (Rhode Island)
VR-RI-0022-9000
Pellegrino, David J (Rhode Island)
VR-RI-0022-9000
Rawson, Christopher M (Rhode Island)
VR-RI-0022-9000
Taylor, Robert K (Rhode Island)
VR-RI-0022-9000
Other Lawyers None on record

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