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VIRGINIA BEACH CITY COUNCIL
Virginia Beach, Virginia
May 11, 2021
Mayor Dyer called to order the CITY COUNCIL'S BRIEFING in the Virginia Beach Convention Center,
Suite 5, Tuesday, May 11, 2021, at 3:00 P.M.
Council Members Present:
Michael F. Berlucchi, Mayor Robert M. Dyer, Barbara M. Henley,
Louis R. Jones, John D. Moss, Guy K. Tower, Rosemary Wilson, Vice
Mayor James L. Wood and Sabrina D. Wooten
Council Members Absent:
Jessica P.Abbott—Arrived at 3:01 P.M
Aaron Rouse —Arrived at 3:05 P.M
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
3:00 P.M.
Mayor Dyer welcomed Christopher S.Boynton,Deputy City Attorney. Mr. Boynton expressed his
appreciation to City Council for their continued support.
St I
4.4
Potential Changes to
City's Election System
CHRISTOPHER S.BOYNTON
DEPUTY CITY ATTORNEY
VIRGINIA BEACH CITY COUNCIL WORKSHOP
MAY 11,2021
Here is the Outline for today's presentation:
Outline
History
• Current Election System
• Holloway Case History
General Assembly Action
Holloway Opinion & Order
Options for Council
Communication Plan
Next Steps
2
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
The next two(2)slides provide a History of the City's voting system:
History
1963 Modern City of Virginia Beach created by merger
Post-merger,City's election system had 7 boroughs
Six magisterial districts of Princess Anne County each elected one member by
and from the district
Former City of Virginia Beach became single district with five members elected
by and from the district
1967 Dusch v. Davis SCOTUS case
Resulted in 7-4 system that became foundational framework for current system
Seven members reside in each of the seven districts;all seven elected at-large
("residence districts")
Four members elected by and from the city at-large
1988 City adopted at-large election of mayor
Previously chosen by City Council members
History
1990 Mayor's Commission recommended seven districts of equal population with one
Council member elected from and by the voters of each district("wards")
(4 at-large, 11 total Council members)
1994 Referendum passed supporting equal population of districts and
implementation of seven wards
- City Council passed resolution asking General Assembly to change City
Charter to require equal population and implement wards
1995 General Assembly granted equal population requirement for residence districts
but declined to implement wards
Directed City to conduct another referendum in 1996
1996 Second referendum supported residence districts over wards
1997 U.S.District Court ruled City's election system did not violate§2 of VRA
2008 Local elections moved from May to November
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
Here is an overview of the Current Election System:
Current Election System
• Existed in current form since 1996 (substantially same since 1967)
• Governed by City Charter§3.01 (enacted by General Assembly)
11 members
4 members(Ind mayor)elected at large(may reside anywhere in city)
7 members elected at large(must reside in one of 7 districts)
Residence districts of approximately equal population
• District boundaries adjusted after each decennial census
• School Board elected using same method (City Charter§16.04)
Chair elected by members of School Board, not public
Chair does not have to be an at large member
Here are Criticisms of Current Election System:
Criticisms of Current Election System
Historically, a primary critique:At-large election of all 11 members
dilutes votes of minority groups
Majority gets to elect all 11 members of Council
Example
If Virginia Beach had 100 voters
70 white,20 Black,5 Asian, 5 Hispanic
If voting was racially polarized,candidates supported by white majority
would always win all 11 seats
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
The next two(2)slides provide examples of At Large and Ward election systems:
At Large
All voters Elect All Council members
• • * eel,
imer.
lop IS
• • •
Ward System
Voting Council
Districts Voters in Each Ward Elect Their Representatives
Individual Council Representative •
•
I
• •
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
Here is an overview of Response to Criticism of System:
Response to Criticism of System
Historically- not possible to draw a majority-minority district for a single minority
in Virginia Beach
Virginia Beach is one of most racially integrated(least segregated)larger cities in America
Minority communities are dispersed throughout city
Not feasible through 2010 redistricting process to draw a district in which a single minority
would constitute a majority in that district
Virginia Beach minority communities are not politically cohesive
Not accurate to say majority of Black,Asian and Hispanic voters prefer same candidates
Combining minority groups into districts would not advance candidates preferred by single
minority
Plaintiffs in Holloway case assert that Black,Asian and Hispanic voters in
Virginia Beach are politically cohesive and that a combined minority-majority
map would address vote dilution
The City is ranked as one of America's Least Segregated Cities:
America's Least
Segregated Cities
7.
Source:U.S.Census Bureau,White to Non-White Racial Dissimilarity
Index IRACEDISPARITYL retrieved from FRED,Federal Reserve Bank of St.Louis;
https://fred.stkwisfed.org/series/RACEDISPARIT\,August 10,2020 via
CityObservatory.org.
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
Here is an overview of Recent Developments Affecting the City's Election System:
Recent Developments Affecting the
City's Election System
Holloway et al. v. City of Virginia Beach Opinion & Order
Case filed in United States District Court in 2017
Trial October 6-14,2020
Court's Opinion March 31, 2021
2021 Changes to Virginia Law
HB2198
HB1890/SB1395
Here is an overview of the Holloway v. City of Virginia Beach trial:
Holloway v. City of Virginia Beach
Plaintiffs Latasha Holloway and Georgia Allen
Now represented by Campaign Legal Center,a D.C.public interest law firm
Key allegation—City's at-large election system violates Section 2 of
federal Voting Rights Act
Dilutes minority voting strength
Prevents a combined group of Black,Hispanic and Asian minority groups from
electing candidates of their choice("coalition"claim)
City disputes facts alleged and legal assertions
Bench trial October 6-14,2020
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
The next two (2)slides provide an overview of recent Bills adopted by the General Assembly:
Virginia House Bill 2198
Adopted by 2021 Virginia General Assembly
Notwithstanding any other provision of law, general or
special, in a locality that imposes district-based or ward-
based residency requirements for members of the governing
body, the member elected from each district or ward shall be
elected by the qualified voters of that district or ward and not
by the locality at large.
Also applicable to School Boards
Virginia Voting Rights Act (HB1890 & SB1395)
Adopted by 2021 Virginia General Assembly
An at-large method of election, including one that combines
at-large elections with district-or ward-based elections, shall
not be imposed or applied by the governing body of any
locality in a manner that impairs the ability of members of a
protected class, as defined in § 24.2-125, to elect candidates
of its choice or its ability to influence the outcome of an
election, as a result of the dilution or the abridgement of the
rights of voters who are members of a protected class.
Establishes pre-clearance process with State Attorney General
Also applicable to School Boards
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
Here is the Combined Effect of 2021 General Assembly Actions:
Combined Effect of 2021 General
Assembly Actions
Even without Holloway case...
Current system must change for 2022 election
7 residence districts become wards without further action by General Assembly
Citizens will no longer elect all 11 City Council representatives
Vote on single representative for their ward and at large seats including Mayor
3 at large districts under current system subject to potential later challenge in
state court even if City prevails in appeal
The District Court found the City's election system is unlawful:
Holloway v. City of Virginia Beach
District Court's Opinion and Order(March 31, 2021)found that
City's election system violates Section 2 and is unlawful:
By a preponderance of the evidence, Plaintiffs have demonstrated that the
at-large system of elections for the Virginia Beach City Council denies
Hispanics,African Americans,and Asians equal access to the electoral and
political process, in contravention of Section 2 of the Voting Rights Act.
Prohibits further elections under current system
Court to determine appropriate remedy in future phase of litigation
Court to award attorneys'fees and costs to Plaintiffs(subject to
later determination of amount)
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
Here is a summary of the Holloway Case Status:
Holloway Case Status
District court has thrown out current election system
Plaintiffs preparing petition itemizing attorneys'fees and litigation
costs per court's order
Seeking at least $3.88 million
City and Plaintiffs preparing for future hearings on remedy phase
City has filed notice of appeal to preserve appellate option
Here are the Holloway Case Appellate Issues:
Holloway Case Appellate Issues
Whether minority groups may be Other appellate considerations
combined to state claim under Section 2 • Appellate outcomes involve high
as a matter of law level of uncertainty; no outcome can
U.S.Supreme Court has not ruled on
viability of"coalition"claims be reliably predicted
Fourth Circuit has suggested,but not • Expensive and time consuming to
formally ruled,that it did not approve of reach final result even if favorable
"coalition"claims • Next general City Council election is
Other circuits are split November 2022;Candidates need to
Whether those minority groups in know system and districts early in
Virginia Beach tend to support the same 2022
candidates as a matter of factual proof
Standing,mootness and ripeness of
Plaintiffs'claims
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
This chart provides an example of Possible Remedies for Section 2 Violation:
Possible Remedies for Section 2 Violation
Change some or all at-large Council positions to ward or super
ward seats. Residence districts function as at-large positions.
ResidencL Ward Super Wart. Minority populations can
District Larger geographical area represent a greater
within city that overlaps proportion of a ward than
two or more wards entire city;therefore,
Each candidate must Each candidate Each candidate greater ability to elect
reside within the must reside within must reside within preferred candidate.
district geographical boundary geographical Plaintiffs:remedial plan
of district they serve boundary of district should create at least
they serve two districts in which
Elected by voters of Elected solely by Elected solely by minority groups could
the entire city registered voters registered voters elect preferred
residing within that residing within that candidates('opportunity
distnds')-
district district
Here is an overview of the Settlement Proposal:
Note:Any settlement must be reviewed
Settlement Proposal and approved by the district court,
which will have authority over election
system for at least 10 years
New 7-3-1 Election System
7 members,1 residing in each of 7 districts(wards),elected only by voters residing in
each ward
3 members,1 residing in each of 3 super wards,elected only by voters residing in each
super ward
1 mayor,elected at-large by all registered voters within the city
At least 3 of 10 districts drawn to create minority opportunity districts
Current discussion focuses on 2 of 7 districts and 1 of 3 super ward
Parties must agree on joint plan(maps)or settlement fails
Plaintiffs'attorneys'fees and costs reduced to$1.6M
Pay within 11 days after court approval of consent decree and joint maps
Plaintiffs claim$3.88M fees and costs to date,additional amounts accruing through
remedial phase and appeal if settlement effort unsuccessful
City retains right to appeal if settlement process not successfully concluded
by July 15, 2021
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
The next two (2)slides provide Concept Maps of a Ward System:
IP Nee
irgir is Beach
it.
7 Wards
kINPViU1
Concept Map
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A . Y` + - Note This maps meant as
«.A fellbo* ', o conceptual illustration of
;� r seven wards and does not
necessarily reflect intended
-". district lines
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Virginia Beach
N.'`: r 3 Super Wards
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.___ \ .. *s- +k Note:This map is meantas a conceptual
! , t illustration of three super wards and does not
a. R necessarily reflect intended district lines.
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2]
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
Here is Joint Plan (Maps)Process:
Joint Plan (Maps) Process
Initial settlement concept: Current settlement concept:
wait for 2020 Census data(fall Draw final maps using 2015-19
2021)before drawing final maps American Community Survey
data
Rationale:2020 Census data is most
accurate data and any maps must be Resolution:Plaintiffs agree to be bound
adjusted using that data to 7-3-1 system using final maps drawn
Challenge:Case is unresolved through using ACS 2015-19 data
the fall,imperiling appeal timeline if Solves appellate timeline problem by
settlement fails allowing parties to reach finality on
system by July 15,2021
Plaintiffs assert that only technical
population and precinct boundary
tweaks will be needed after receipt of
2020 Census data;City expert agrees
T3
Settlement Proposal re: Appeal
Appeal stayed through July 15, 2021 as parties and court consider
settlement. Stay is lifted if:
Council votes not to approve settlement on June 15, 2021
Parties cannot agree on joint proposed district maps for 7-3-1 plan
Court does not accept 7-3-1 plan/maps on or before July 15, 2021
Plaintiffs agree to expedite City's appeal if court has not approved
proposed consent decree and joint maps on or before July 15, 2021
Note:Any settlement must be reviewed and
approved by the district court
24
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
The next two (2)slides provide settlement Options:
Options
Reject Settlement/Appeal Reject Settlement/No Appeal
If City prevails(and without further changes Court likely to implement 10-1 ward system
by General Assembly): Plaintiffs requested
7 members
•
- one residing in each of seven wards 10 representatives
elected only by registered voters residing in • one residing in each of 10 wards
each ward
Residence districts no longer viable due to elected only by the registered voters
HB2198 residing in each ward
4 members,including mayor • Remedy would likely require at least 2 of
may reside anywhere in city 10 ward districts be minority opportunity
elected at large by all registered voters in city districts
Remaining at-large districts subject to Mayor could still reside anywhere in the
possible future challenge under Virginia City and would be elected at-large
Voting Rights Act(HB1890/SB1395)
Note:District court likely to implement 10-1 ward
system while appeal is on-going
zs
Options
Reject Settlement&Appeal Approve Settlement
Pros • Pros
7-3-1 system allows each citizen to vote
for three council members
Defend principle that City's current election
system does not violate VRA Section 2 Resolves Voting Right Act Section 2
concerns as well as state law issues
No ongoing federal court involvement in City's Provides certainty by July 15,2021
election system
Saves at least$2.3 million,plus costs of
Cons appeal for(potentially)both parties
District court likely to implement 10-1 system Cons
during appeal(can seek stay of remedy) - No appellate court determination of
Costly/time consuming;Council elections in 2022 whether district court was correct
Uncertain outcome Ongoing federal court involvement in
Best:7 ward,4 at-large system with potential City's e l ection system
for future litigation regarding at-large seats Still potentially subject to state AG
and subject to state AG preclearance preclearance
Worst:10-1 system remains in place,
significantly higher attorneys'fees and costs 15
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
Here is the Impact on School Board Elections:
Impact on School Board Elections
School Board is not a party in Holloway case
Ruling refers only to City Council elections
By City Charter, School Board members are elected in same manner and
according to same schedule as Council members
HB2198 changes School Board's residence districts to wards
Most likely result: System adopted by district court will apply to School Board
Ambiguity as to 11th School Board member
School Board has 7 district and 4 at large members
School Board chair is selected by Board,not by the public
Charter change likely required after new City Council system is determined
Here is the proposed Public Information and Input schedule:
Public Information and Input
Council Goal: Use variety of City channels to disseminate information and
provide residents with opportunities to provide feedback.
In Person Digital/Media/Virtual
Public Briefings - Virtual Town Hall
May 11 Council Chamber • VBGov.com—headlines, update case
June 1 Council Chamber page on site
Other:Time and Place TBD • City Page
Council Townhalls/Community Meetings • City Manager Update
As determined or requested by • Direct Mailing
Councilmembers
• Media briefings/placements
Public Hearings • Social Media(Facebook,Twitter,
June 8 NextDoor,YouTube, Instagram)
June 15(Council vote) • VBTV
19
May 11, 2021
CITY COUNCIL'S BRIEFING
POTENTIAL CHANGES TO THE CITY'S ELECTION SYSTEM
(Continued)
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Potential Changes to
City's Election System
CHRISTOPHER S. BOYNTON
DEPUTY CITY ATTORNEY
VIRGINIA BEACH CITY COUNCIL WORKSHOP
MAY 11,2021
Mayor Dyer expressed his appreciation to Mr. Boynton for the presentation.
*Council Member Moss requested to have his typed comments added to the record, attached hereto
and made a part of the record.
May 11, 2021
Your narrative is that independent of this suit that the State Votings Act independent of the
Fowler Act drives us to a ward voting.
Answer: An at-large election system or at-large component of an election system is
prohibited under the state version of the VRA if there is evidence that there is racially
polarized voting in the locality and the at large system dilutes the voting strength of a
protected class. See Va. Code §24.2-130. This is similar to but broader than the test under
the federal version of the VRA and thus even were the City to prevail on appeal in the
federal case, it would be less likely that the City could successfully defend an at large
system under the state VRA.
Your narrative suggest that even the Fowler Act which would enable us to preserve the true all
at-large seats with seven wards would be subject to challenge under the enacted State Voting
Rights Act.
Answer: Although HB 2198 leaves open the possibility of eliminating the residence districts
and going to an all at large system, as you are aware such a change would require a charter
amendment by the General Assembly and compliance with the pre-clearance process
established in the new state VRA. Even if those steps were to occur, for the reasons stated
in response to you prior question, such a change would be subject to a future claim that it
violated Section 24.2-130 of the Virginia Voting Rights Act.
You have provided narrative that has stated that while the text of the State's Voting Rights Act is
not on its face unconstitutionally suspect with regard to the equal protection clause of the U.S.
Constitution, a specific application of the interpretation and application of the State's Voting
Rights Act provisions with regard to the further undefined"influence districts"could run around
afoul if the equal protection clause thus being constitutionally vulnerable.
Answer: There could potentially be both facial and as applied challenges to portions of the
new state VRA,including claims under the equal protection clause.
You have provided narrative that the U.S. Supreme Court has yet to establish to establish that a
combination of minorities can be formed and under what evidentiary standards to prove a
violation of section 2 of the Voting Rights Act of 1965 as amended.
Answer: The Supreme Court has not ruled on whether coalition claims are recognizable
under Section 2.
You provided narrative that the U.S. Federal courts have come to different conclusions as to
whether other a singular minority can be used to meet the 50 percent plus 1 standard independent
of addressing the evidentiary standards for validating voting behavior patterns.
Answer: There is a split among the federal circuit courts on this issue.
You have advance that if we were to appeal at Fourth District Appellate.Court and win,
assuming the plaintiffs appealed to the U.S. Supreme Court and one, we would still be subject to
litigation under the State Voting Rights Act.
Answer: If the City were to prevail on appeal in either the Fourth Circuit or the Supreme
Court, plaintiffs or others similarly situated could file a new suit under the Virginia Act
and would face an easier path to judgment because of the more relaxed standard for
liability under the state act (e.g., under Virginia's Voting Rights Act, a Plaintiff need not
prove what is referred to as the first Gingles precondition, that the minority group at issue
is "sufficiently large and geographically compact to constitute a majority in a single-
member district." This likely means that plaintiffs in a state action will not need to rely on
a coalition of minorities to satisfy the VRA requirements.).
Is not a factual finding that if the U.S. Supreme Court were to rule in our favor by finding that
for the purposes of finding a violation of Section 2 of the Federal Voting Rights Act of 1965 as
amended the combination of minorities cannot be used to achieve minority status within the
terms of Federal law that the application of the application of the State's Voting Rights act would
be constrained?
Answer: The state statute would not be directly"constrained." A Virginia court may fmd
a Federal Court's interpretation of the Federal Voting Rights Act informative, but it would
not be bound by those fmdings in interpreting state law. Further, there are differences
between the current federal action and a contemplated state action, because a state plaintiff
would not need a"coalition" of different minority groups. A federal ruling on"coalition"
claims would be of limited relevance.
Your narrative has shared that probability of winning on appeal at the Fourth District Appellate
Court is highly dependent on the luck of the draw of the judges in rotation that would hear our
case and whether it three judges or nine.
Answer: Our case would be heard by a three judge panel and the composition of that panel
will affect the prospects for success.
Your narrative has been that getting a stay from Judge Jackson on the implementation of his
remedy based on his ruling is nil.
Answer: I am advised by our outside counsel that the likelihood of a stay is very low and
this is consistent with my view.
Your narrative has been that securing a stay from the Fourth District Appellate Court is low odds
and from the Supreme Court even lower.
Answer: Again, outside counsel advises that the Fourth Circuit is unlikely to fmd that we
satisfy the standard detailed in response to your next question. Mostly likely we would fmd
it hard to satisfy element(2) because the Fourth Circuit would likely fmd that the appeal
could conclude before any remedy was applied(i.e.,to the November 2022 election) and
thus that the City will not suffer irreparable harm in the absence of a stay. The Fourth
Circuit may fmd we are weak on other points as well. The standard for a Supreme Court
stay is even higher than for a Fourth Circuit stay.
You have not yet shared and now I am requesting you to share as part of public briefing what is
standard/the case we would to make to secure a stay.
Answer: The standard in Federal courts to secure a stay is:
1. whether the defendant has a strong or substantial likelihood of success on the
merits;
2. whether the defendant will suffer irreparable harm if the district court proceedings
are not stayed;
3. whether staying the district court proceedings will substantially injure other parties;
and
4. where the public interest lies.
For a Supreme Court stay,we would have to show, beyond these factors,that the Supreme
Court is likely to grant certiorari,which it does in a small number of cases, and to rule in
our favor.
The reasoning being offered to settle and accept a Judge Jackson's supervision of redistricting
and elections for years to come (narrative off your briefing material) is that even if we prevail on
the merits we likely would still get ten districts and the"deal" allows the retention of a
resemblance of at-large seats with three super wards.
Answer: That is a possibility but not a certainty. If the City were to prevail on appeal, it
would start at 7 wards with 4 at large seats. Those at large seats could be challenged under
state law, as discussed above, but the success of that suit would depend on multiple factors,
including whether the 7-4 system has been drawn to allow two or more minority
opportunity districts among the seven wards. My belief is that the 10 -1 system is what will
be imposed by the federal court if we neither settle nor win on appeal.
Is it not a fact, that if we prevail on appeal that we the City in its redistricting efforts and the
operation of its election the City would not be under the supervision of a Federal Court?
Answer: This statement is correct.
Is it not a fact, that if we prevail on appeal that we the City in our compliance with the State
Votings Act would have increased constitutional defenses against the applications of the
ambiguous "influence districts"provisions?
Answer: The City would have defenses and arguments regarding the ambiguity and
overbreadth of the state VRA if a lawsuit was brought against the City under that Act. It is
possible that language in a favorable appellate ruling could help clarify those defenses but
that is not a certainty as the federal appellate court would be basing its ruling on Section 2
of the Federal Act and not on the more broad language in the state VRA. Additionally, the
constitutional challenges to certain applications of the State Voting Rights Act will exist
regardless of the contemplated appeal.
ADJOURNMENT
Mayor Robert M. Dyer DECLARED the City Council Meeting ADJOURNED at 4:29 P.M.
r
Terri H. Chelius
Chief Deputy City Clerk
r
A arnes, M
City Clerk
May 11, 2021