Plaintiff Carolyn Coleman, age 71, is an African-American elected commissioner who resides in Guilford County, North Carolina, and has been engaged in voter outreach and education for nearly 50 years. Ms. Coleman has spent time on college campuses encouraging students to vote and has worked to make voter registration more accessible to the public by setting up tables at shopping centers, football games and other large events to register people to vote. Ms. Coleman plans to continue to be actively engaged in voter education, registration and outreach. Also, in her elected office, Ms. Coleman represents a constituency (Greensboro) with a significant African-American population, and plans to run for reelection in 2014. Ms. Coleman will be forced to incur additional costs during her reelection campaign in order to assist members of the community to register to vote, and to educate the community on the additional restrictions on voting imposed by HB 589.Coleman ran unopposed in her last election, in 2010.
Plaintiff Emmanuel Baptist Church is located in Winston-Salem's Columbia Heights neighborhood. The church is led by Dr. John Mendez and is committed to minister "to the social needs of the community," which includes ensuring its community members' participation in the political process and their right to vote. The church's social action committee organizes voter registration drives; provides transportation in vans owned and operated by the church for members of the congregation and community to register and to vote; and conducts "Souls to the Polls" initiatives through which the church transports to the polls hundreds of registered voters and other individuals seeking to register and vote.
Plaintiff Emmanuel Baptist Church has standing to sue on its own behalf. The reduction in early-voting days in HB 589 will place a strain on the church's transportation services, will make it difficult for the church to operate the programs they have in the past, and will lead to a reduction in the number of voters and congregants that the church is able to transport to the polls. Emmanuel Baptist Church must now diver substantial resources and attention away from other critical mission to assist members of its congregation, the residents of the surrounding community it serves, and other constituents who stand to have their right to vote burdened by the law.
Plaintiff Jocelyn Andreka Ferguson-Kelly, age 19, is an African-American student, majoring in clinical laboratory science at Winston-Salem State University,a historically black college in North Carolina. Ms. Ferguson-Kelly is registered to vote in North Carolina and voted in 2012 at the polling place on campus. Ms. Ferguson-Kelly does not have a North Carolina driver's license and does not possess any other form of accepted identification under HB 589. Ms. Ferguson-Kelly plans to vote in the 2014 elections and will have to incur substantial time and expense to obtain the required identification. Ms. Ferguson-Kelly voted as a qualified voter in the 2012 election; however, HB 589's voting restrictions will render her ineligible to vote unless she obtains the required identification.
Plaintiff Faith Jackson, age 20, is an African-American student, majoring in nursing at Winston-Salem State University, a historically black college in North Carolina. She is registered to vote in North Carolina and voted in 2012 at a precinct on campus. Ms. Jackson does not have any of the forms of accepted identification to vote under HB 589. Ms. Jackson plans to vote in the 2014 elections and will have to incur substantial time and expense to obtain the required identification. Ms. Jackson voted as a qualified voter in North Carolina during the 2012 general election; however, HB 589's voting restrictions will render her ineligible to vote unless she obtains the required identification.
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