SI- Wandering Medicine v. McCulloch 2012

You may view the statement of interest in pdf format.

 

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THOMAS E. PEREZ

Assistant Attorney General Civil Rights Division

T. CHRISTIAN HERREN, JR BRYAN L. SELLS

Attorneys Voting Section, Civil Rights Division

U.S. Department of Justice

Room 7264 NWB

950 Pennsylvania Avenue, N.W.

Washington, D.C. 20530

Telephone: (202) 353-0792

Facsimile: (202) 307-3961

bryan.sells@usdoj.gov

Attorneys for the United States

 

MICHAEL W. COTTER

United States Attorney

VICTORIA L. FRANCIS

Assistant U.S. Attorney

U.S. Courthouse

2601 Second Avenue North

Box 3200

Billings, MT 59101

Telephone: (406) 247-4633

Facsimile: (406) 657-6989

victoria.francis@usdoj.gov

 

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA

BILLINGS DIVISION

MARK WANDERING MEDICINE, et al.,

Plaintiffs,

v.

LINDA McCULLOCH, in her official capacity as Montana Secretary of State, et al.,

Defendants,

 

CASE NO. 1:12-CV-135-RFC

STATEMENT OF INTEREST OF THE UNITED STATES OF AMERICA

 

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The United States respectfully submits this Statement of Interest pursuant to 28 U.S.C. § 517, which authorizes the Attorney General to attend to the interests of the United States in any pending suit. The United States has a strong interest in the resolution of this matter because it implicates the proper interpretation and application of Section 2 of the Voting Rights Act, 42 U.S.C. § 1973. See 42 U.S.C. § 1973j(d) (authorizing the Attorney General to enforce Section 2 on behalf of the United States).

The plaintiffs’ complaint alleges, among other things, that the location of the site for in-person late registration and early voting in Big Horn, Blaine, and Rosebud counties discriminates against Native Americans in violation of Section 2. Compl. ¶¶ 161-63, ECF No. 1. The plaintiffs seek a preliminary injunction requiring the defendants to open one additional site in each county that will provide Indian voters with greater access to the political process. Id. at 39-40.

The purpose of this brief is to supply the Court with expert analysis demonstrating that Native Americans in the affected counties have significantly less access to in-person late registration and early voting than their white counterparts. This evidence, along with the evidence adduced by the plaintiffs,establishes that the plaintiffs are likely to succeed on the merits of their Section 2 claim.

 

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I. BACKGROUND

This case involves two provisions of Montana election law that make it easier for Montanans to exercise their electoral franchise. The first is known as “late registration,” and the second is known as “early voting.” Together, the two provisions offer convenient one-stop approach to registration and voting that allows a voter to register and vote with a single visit to a local office any time within a 30-day window preceding an election.

Late registration is an option for Montanans who miss the regular mail-in registration deadline 30 days before an election. Se Mont. Code. Ann. § 13-2-301. Starting the day after the regular registration deadline and continuing until the close of the polls on Election Day, an eligible voter may register to vote or update the voter’s existing registration information by appearing in person at the county election office or other location designated by the county election administrator. See Mont. Code Ann. § 13-2-304.

Early voting, which is also known as in-person absentee voting, allows any registered voter to receive, mark, and submit an absentee ballot in person at the county election office or other location designated by the county election administrator. See Mont. Code. § 13-13-222. The early-voting period begins as soon as absentee ballots become available—which is typically about 30 days

 

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before the election—and continues until noon on the day before the election. See Mont. Code Ann. §§ 13-13-205, -211. Although late registration and early voting most often take place at the county election office, which is usually located in the county clerk’s office in the county seat, Montana law permits a county to create satellite election offices so that late registration and early voting can take place in more than one location. Pls. Mem. Supp. Mot. Prelim. Inj. Ex. 9 (Election Advisory #A01-12), ECF No. 4-2.

Big Horn, Blaine, and Rosebud counties currently offer late registration and early voting only in the county seat. Each of those counties is geographically large and sparsely populated. Each of those counties also has a substantial Native American population, most of which lives on or near Indian reservations located within those counties at a great distance from the county seat.

II. ARGUMENT

Plaintiffs seeking a preliminary injunction must establish that they are likely to succeed on the merits, that they are likely to suffer irreparable harm in the absence of preliminary relief, that the balance of equities tips in their favor, and that an injunction is in the public interest. Winter v. Natural Res. Def. Council, Inc., 555 U.S. 7, 20 (2008); see also Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127, 1131–32 (9th Cir. 2011). The plaintiffs here can meet that standard.

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A. The plaintiffs are likely to succeed on their Section 2 claim.

Section 2 of the Voting Rights Act, 42 U.S.C. § 1973, prohibits voting practices and procedures that result in discrimination on the basis of race, color, or membership in a language minority group. See 42 U.S.C. § 1973(a). It prohibits, for example, unequal access to voter-registration sites, see Operation Push v. Allain, 674 F. Supp. 1245 (N.D. Miss. 1987), aff’d sub nom. Operation Push v. Mabus, 932 F.2d 400 (5th Cir. 1991), and unequal access to voting sites, see Spirit Lake Tribe v. Benson County, 2010 WL 4226614 (D.N.D. Oct. 21, 2010); Brown v. Dean, 555 F. Supp. 502 (D.R.I. 1982). See also Jacksonville Coalition for Voter Protection v. Hood, 351 F. Supp. 2d. 1326 (M.D. Fla. 2004) (unequal access to early voting sites); Brown v. Post, 279 F. Supp. 60 (W.D. La. 1968) (unequal access to absentee voting opportunities).

A violation of Section 2 is established “if, based on the totality of circumstances, it is shown that the political processes leading to nomination or election in the State or political subdivision are not equally open to participation by members of a [racial or language minority group] in that its members have less opportunity than other members of the electorate to participate in the political process and to elect representatives of their choice.” 42 U.S.C. § 1973(b). See generally Thornburg v. Gingles, 478 U.S. 30, 43-46 (1986) (discussing Section 2 and its legislative history). When evaluating the totality of circumstances, there is

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no requirement that any particular number of factors be proved or that a majority of them point one way or the other. See id. at 45. Rather, “the question whether the political processes are ‘equally open’ depends upon a searching practical evaluation of the ‘past and present reality.’” Id. (quoting S. Rep. No. 97-417, at 30 (1982)).

The attached declaration of Professor Gerald R. Webster, chair of the geography department at the University of Wyoming, demonstrates that Native Americans in Big Horn, Blaine, and Rosebud counties have significantly less access than whites to late registration and early voting. See Ex. 1 at 3-4, 9 (Webster Decl.). Professor Webster calculated the average distance to the single late registration and early voting site in each county for Native Americans and whites, and he found large and statistically significant racial disparities in each county. Table 1 below summarizes Professor Webster’s findings. In short, Native Americans in the three counties have to travel much greater distances than their white counterparts to access the site in their respective counties.

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Table 1
Mean Distance to County Courthouse for Voting-Age Residents, in Miles
                                            Whites                  Indians                Disparity

Big Horn County                    11.61                     22.02                    189%
Blaine County                         9.77                      31.45                    322%
Rosebud County                     16.79                    44.85                    267%

Source: Ex. 1 (Webster Decl.) at 9.

 

Professor Webster also found that Native Americans in the three counties have substantially higher poverty rates and substantially lower access to vehicles than their white counterparts. See Ex. 1 at 2-3, 7-8 (Webster Decl.). In Big Horn and Blaine counties, for example, Native Americans are more than twice as likely as whites to be in poverty, and in Rosebud County, which also has the largest disparity in travel distances, the disparity in poverty rates is greater than 400%. Similar disparities obtain in access to vehicles. In Big Horn and Blaine Counties, Native American households are more than three times as likely as white households to lack access to a vehicle. In Rosebud County, the disparity is greater than 200%. These two factors suggest that Native Americans are much more likely to lack the resources necessary to overcome the greater distances to their late registration and early voting site.

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Finally, and for illustrative purposes only, Professor Webster calculated what the average distance to the nearest early voting site would be if each county were to open a satellite office as the plaintiffs request. See Ex. 1 at 4-5, 10 (Webster Decl.). He found that the satellite office would greatly reduce both the average distance for Native Americans and the racial disparity in each county. This demonstrates the availability of a remedy that would provide Indian voters in the three counties with much greater electoral opportunity.

The statistical evidence contained in Professor Webster’s declaration is highly probative of a Section 2 violation not merely because it demonstrates racial disparities in access to the polls but because the racial disparities it demonstrates are so extreme. Native American voters in the three counties are much farther from the late registration and voting site than their white peers, and they are much less likely to have the resources necessary to bridge the gap.

Other available evidence further supports the conclusion that the plaintiffs are likely to succeed on the merits of their Section 2 claim. The plaintiffs’ complaint and brief in support of their motion for a preliminary injunction points to some of this evidence, including the history of discrimination against Native Americans in Montana, the underutilization of absentee voting in the three challenged counties, socioeconomic disparities, and the great distances that Indians must travel to take advantage of the electoral opportunities available to their white

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counterparts. The Court may also take judicial notice of relevant findings made in other Montana voting-rights cases on behalf of Indians such as United States v. Blaine County, 363 F.3d 897, 912-914 (9th Cir. 2004) (discussing the history of discrimination and other totality-of-circumstances factors in Blaine County); Old Person v. Cooney, 230 F.3d 1113, 1129 (9th Cir. 2000) (discussing totality-of-circumstances factors in a challenge to statewide redistricting); and Windy Boy v. Big Horn County, 647 F. Supp. 1007, 1007-08 (D. Mont. 1986). This other evidence is “supportive of, but not essential to,” the plaintiffs’ claim. Gingles, 478 U.S. at 48 n.15.

The practical reality is that Indian voters in Big Horn, Blaine, and Rosebud counties do not have the same opportunity as white voters to take advantage of late registration and early voting. Indeed, this case presents extreme factual circumstances. The totality of the evidence before the Court thus establishes that the plaintiffs are likely to succeed on the merits of their Section 2 claim.

B. Native Americans in the three counties will suffer irreparable harm in the absence of immediate injunctive relief.

Denial or abridgment of the equal right to vote constitutes irreparable harm. See Obama for America v. Husted, 2012 WL 4753397 (6th Cir. Oct. 5, 2012); Williams v. Salerno, 792 F.2d 323, 330 (2d Cir. 1986) (voters “would certainly suffer irreparable harm if their right to vote [was] impinged upon.”); U.S. Student

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Ass’n Found. v. Land, 585 F. Supp. 2d 925, 944 (E.D. Mich. 2008) (“any disenfranchisement effected by the undeliverable ID or driver's license practices would indeed constitute irreparable harm.”); Montano v. Suffolk Cnty. Legislature, 268 F. Supp. 2d 243, 260 (E.D.N.Y. 2003) (“An abridgement or dilution of the right to vote constitutes irreparable harm.”); United States v. Berks County, 250 F. Supp. 2d 525, 540-41 (E.D. Pa. 2003); Harris v. Graddick, 593 F. Supp. 128, 135 (M.D. Ala. 1984).

Part of the reason for this treatment of voting harms is the special importance of the right to vote in the American democratic tradition:

Reynolds v. Sims, 377 U.S. 533, 561-62 (1964); accord Wesberry v. Sanders, 376 U.S. 1, 17 (1964) (“No right is more precious in a free country than that of having a voice in the election of those who make the laws under which, as good citizens, we must live.”). Money cannot fully compensate an individual for the loss of a right so fundamental. Part of the reason is also practical: a court simply cannot undo—by means of a special election or otherwise—all of the effects of an election

 

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infected with racial discrimination. See Sprit Lake Tribe, 2010 WL 4226614 at *4-*5.

In this case, the irreparable harm is clear. Without an injunction, Native Americans in Big Horn, Blaine, and Rosebud counties will not have the same electoral opportunities as their white counterparts.

C. The balance of the equities tips in the plaintiffs’ favor.

The relief that the plaintiffs seek here is appropriately tailored to the defendants’ violation of federal law. They seek an order requiring the defendants to open a satellite office in each county that is accessible to Indian voters. While a permanent remedy could potentially entail a single site in each of three counties that is equally accessible to all residents in each of these counties, this preliminary remedy avoids the confusion that could result from moving the one existing site in each county to a more appropriate location on the eve of the election.

In addition, the preliminary remedy will not entail significant costs to the defendants because there are so few days remaining until the election and because, as is evident from the correspondence attached to the plaintiffs’ brief, the plaintiffs have offered to cover the cost of operating those sites. As a result, the requested relief is unlikely to pose a significant burden on the defendants over the few days remaining before Election Day. Whatever burden there might be is easily outweighed by the risk of harm to Indian voters in the three affected counties.

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The balance of the equities therefore favors the plaintiffs.

D. The public interest favors immediate injunctive relief.

The public interest also favors the plaintiffs. Section 2 represents “a strong national mandate for the immediate removal of all impediments, intended or not, to equal participation in the election process.” Harris, 593 F. Supp. at 135. Ordering the defendants to provide Indian voters with the same electoral opportunities they provide white voters “serves the public interest by reinforcing the core principles of our democracy.” Berks County, 250 F. Supp. 2d at 541.

Moreover, the public has a clear interest in the enforcement of Federal statutes that protect constitutional rights, including voting rights. United States v. Raines, 362 U.S. 17, 27 (1960) (reversing denial of preliminary injunction in voting rights case and holding that “there is the highest public interest in the due observance of all the constitutional guarantees, including those that bear the most directly on private rights”); United States v. E. Baton Rouge Parish Sch. Bd., 594 F.2d 56, 58 (5th Cir. 1979) (“[T]he United States has an interest in enforcing Federal law that is independent of any claims of private citizens. In the [voting rights] context the Supreme Court has characterized this as the highest public interest in the due observance of all constitutional guarantees.’ (quoting Raines, 362 U.S. at 27)); U.S. Student Ass’n Found. v. Land, 585 F. Supp. 2d 925, 947 (E.D. Mich. 2008) (noting in the voting context that “the public has an interest in

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the enforcement of federal statutes.”) (internal citations and quotations omitted); see Herman v. S.C. Nat’l Bank, 140 F.3d 1413, 1425 (11th Cir. 1998) (discussing E. Baton Rouge Parish Sch. Bd., 594 F.2d at 58); see also Summit Cnty. Democratic Cent. and Exec. Comm. v. Blackwell, 388 F.3d 547, 551 (6th Cir. 2004) (“There is a strong public interest in allowing every registered voter to vote freely.”).

III. CONCLUSION

For the foregoing reasons, the Court should grant the plaintiffs’ motion for a preliminary injunction.

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Date: October 24, 2012

Respectfully submitted,

MICHAEL W. COTTER                       THOMAS E. PEREZ

United States Attorney                     Assistant Attorney General

VICTORIA L. FRANCIS                       Civil Rights Division

Assistant U.S. Attorney

District of Montana                          /s/ Bryan L. Sells ____

                                                         T. CHRISTIAN HERREN, JR.

                                                          BRYAN L. SELLS

                                                          Attorneys

                                                          Voting Section

                                                          Civil Rights Division

                                                          U.S. Department of Justice

                                                          Room 7264 NWB

                                                          950 Pennsylvania Avenue, N.W.

                                                          Washington, D.C. 20530

                                                          Telephone: (202) 353-0792

                                                          Facsimile: (202) 307-3961

                                                           Counsel for the United States

 

An Evaluation of the Effects of Adding a Second Voter Registration/Polling Site in Three Montana Counties

Professor Gerald R. Webster

Department of Geography

University of Wyoming

I am a professor of geography at the University of Wyoming, Laramie, Wyoming, where I also serve as the departmental chair. Prior to moving to the University of Wyoming in 2007, I was a faculty member in the Department of Geography at the University of Alabama for eighteen years, serving as chair the last seven years. My formal education includes a BA (1975) in political science from the University of Colorado-Denver, a MS (1980) in geography from Western Washington University, and a Ph.D. (1984) in geography from the University of Kentucky.

My primary research and teaching interests are in political geography including electoral geography. I have authored or co-authored over 100 items including approximately 75 refereed journal articles and book chapters including many on electoral landscapes and redistricting. In November, 2011, I received the Outstanding Lifetime Achievement Award from the Southeastern Division of the Association of American Geographers. I have served as a consultant and expert witness on election related litigation since the mid-1990s for clients in Alabama, Mississippi, Louisiana, Florida, North Carolina, Virginia, Texas and Illinois.

On October 18th, 2012, I was contacted by the U.S. Department of Justice about potential litigation involving three counties in Montana: Big Horn, Blaine and Rosebud. Each of the three counties has a single site for voter registration and voting at their county courthouses. Each of the three counties includes all or portions of the Crow (Big Horn), Northern Cheyenne (Rosebud), and Ft. Belknap (Blaine) Indian Reservations. The tribal leaders at each of these

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reservations have requested a second site for voter registration to facilitate greater access to the polls for American Indian residents in each county. I have been asked to examine three questions:

I personally compiled the two tables to address question 1. The GIS analysis and statistical calculations to address questions 2 and 3 were completed by the University of Alabama Cartographic Research Laboratory under my direction. I have engaged the services of the Cartographic Research Laboratory since 1989, and they have provided analysis and figures for the overwhelming majority of my litigation related consultancies during the past two decades. Given my work with the Laboratory, I am confident in the quality and accuracy of their work.

Question 1 was addressed using data from the American Community Survey tables B17001 and B25044. First, the poverty status of Anglos (white, non-Hispanic) and American Indians was compared in the three counties (Table 1). Poverty may constitute an obstacle for

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potential voters to participate in the electoral process, most particularly for those residents living long distances from voter registration and polling sites. In Big Horn County 12.2% of the Anglo population had incomes in the past 12 months below the poverty level, while the rate for American Indians in the county was well over double that rate at 28.9%. In Blaine County 16.2% of the Anglo population had incomes in the past 12 months below the poverty level, while the rate for American Indians in the county was two and a half times greater at 41.5%. The greatest contrast was found in Rosebud County in which the poverty rate for American Indians (36.1 %) was over four times the rate for Anglos (8.8%). In all three counties the poverty rate among American Indians is substantially greater than for the Anglo population.

Access to a motor vehicle facilitates an individual's ability to travel to a voter registration or polling site. Table 2 compares Anglo and American Indian access to motor vehicles in the three counties. In Big Horn County 1.9% of Anglos have no vehicle available, while 6.5% of the county's American Indian population have no access to a vehicle. Similarly, while 14.2% of American Indian residents in Blaine County have no vehicle available, the rate for Anglos is far less at 4.1 %. Finally, while 4.0% of Anglos in Rosebud County have no vehicle available, the rate for American Indians is more than double that rate at 8.8%. In each of the three counties the availability of motor vehicles is substantially less for American Indian residents than for Anglo residents.

The second question was addressed by estimating the distance potential Anglo and American Indian voters would have to travel to reach the county courthouse in each of the three counties. The population centroid of each census block group was first calculated using the voting age population in the blocks comprising the block group. The population centroids were then employed as the beginning points to measure the straight line distance to the county

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courthouse, the site for residents to register to vote and to vote. This estimate was used as the distance to the courthouse voting registration and polling site for all Anglo and American Indian voting age residents of the census block group. The same calculations were undertaken in all census block groups in each county and used as the estimated travel distance for Anglo and American Indian residents of voting age. From these calculations estimates of the mean distance for both potential Anglo and American Indian voters to register and vote at the county courthouse were determined.

The estimated mean distance voting age Anglos in Big Horn County must travel to reach the county courthouse is 11.61 miles. This mean is substantially below the estimate for American Indian residents of Big Horn County who on average must travel 22.02 miles to reach the courthouse to register to vote and vote. The contrasts in Blaine are Rosebud counties are even greater. While Anglos on average must travel an estimated 9.77 miles to arrive at the Blaine County courthouse, American Indians in Blaine County must travel an estimated average of 31.45 miles to do the same. Thus, on average American Indians in Blaine County must travel an estimated 22 miles farther than Anglos to reach the courthouse. In Rosebud County Anglos on average must travel an estimated 16. 79 miles to reach the county courthouse, while American Indians must travel an estimated 44.85 miles on average to reach the county courthouse, or on average over 28 miles farther.

The final question to be addressed pertained to the accessibility effects if each of the three counties added a second voter registration and voting site on the reservation in each county. The Department of Justice provided additional potential locations in each of the counties: Little Big Horn College in Big Horn County, Fort Belknap Hospital in Blaine County, and the Northern Cheyenne Tribal Building in Rosebud County (Figures 1-3). Assuming both Anglos

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and American Indians in the three counties will travel to the closest voter registration and polling site whether it be the county courthouse or the new site on the reservation, the mean distances for both groups were recalculated.

The hypothetical addition of a second voter registration and polling site decreased the estimated mean travel distances to one of the two voter registration and polling sites in each of the three counties for both Anglos and American Indians (Table 4). In Big Horn County the estimated mean distance for Anglos was 9 .14 miles, while the estimated mean distance for American Indians was 15.33 miles. The addition of the second site decreases the estimated mean travel distance by 6.69 miles for American Indians in Big Horn County to travel to a registration and polling site. In Blaine County the addition of a second voter registration and polling site also decreased estimated mean travel distance for both Anglos and American Indians. Most significant was the decrease of estimated mean travel distance for American Indians by well over 17 miles with the addition of the second site, though estimated mean travel distance for Anglos also decreased by 4.5 miles. In Rosebud County estimated mean travel distance for Anglos was 10.13 miles and 5.67 miles for American Indians with the addition of the second voter registration and polling site. The addition of the second site in Rosebud County had a dramatic effect on estimated mean travel distance for American Indians, decreasing the average distance by over 39 miles.

Findings

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Table 1

Anglo and American Indian Poverty Status in Big Horn, Blaine and Rosebud Counties, Montana

 

Total American

Total               Poverty              Indian and                Pove1iy County            Anglo               Status*              AK Native                   Status*

 

 

Big Horn	3,929	480(12.2%)	7,347	2,122(28.9%)
Blaine	3,017	488(28.7%)	3, 181	1,320(41.5%)
Rosebud	5,464	482(8.8%)	2,839	1,025(36.1%)

 

*Income in the past 12 months below the poverty level.

 

SOURCE: U.S. Census Bureau, American Community Survey, Poverty Status in the Past 12 Months by Sex By Age, 2010, Table B 17001.

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Table 2

 

Table 2

Vehicle Availability by Housing Type for Big Horn, Blaine and Rosebud Counties, Montana

 

American

Housing      Total        No Vehicle          Indian and       No Vehicle County         Type          Anglo         Available            AK Native          Available

 

Big Horn	Owner Occupied    1,285	23 (1.8%)	915	50(5.5%)
	Renter Occupied       381	9(2.4%)	663	53(8.0%)
	Total            1,666	32(1.9%)	1,578	103(6.5%)
Blaine	Owner Occupied    1,090	10(0.9%)	371	28(7.5%)
	Renter Occupied       325	48(14.8%)	524	99(18.9%)
	Total           1,415	58(4.1%)	895	127(14.2%)
Rosebud	Owner Occupied    1,770	27(1.5%)	439	15(3.4%)
	Renter Occupied     613	69(11.3%)	313	51(16.3%)
	Total          2,383	96(4.0%)	752	66(8.8%)

 

SOURCE: U.S. Census Bureau, American Community Survey, Tenure by Vehicles Available, 2010, Table B25044.

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Table 3

Average Distance to the County Court House for Anglo and American Indian Voting Age Residents in Three Montana Counties

 

	Mean Distance	Mean Distance                    Absolute
County	For Anglos*	For American Indians*           Difference

 

Big Horn	11.61 miles	22.02 miles	10.41 miles
Blaine	9.77 miles	31.45 miles	21.68 miles
Rosebud	16.79 miles	44.85 miles	28.06 miles

 

*In this case I am attempting to demonstrate that the mean distances for American Indians are greater than for Anglos to travel to the county courthouse.  As a result, a one-tailed T test is appropriate.  The one-tailed T tests for the three counties confirmed the differences in travel distance for American Indians and Anglos are statistically significant at the 0.01 level.

 

SOURCE: Calculated by the University of Alabama Cartographic Research Laboratory using data secured from the Bureau of the Census.

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Table 4

Average Distance to the Voter Registration and Voting Sites When a Second Hypothetical Site is Add ed to Each County for Anglo and American Indian

Voting Age Residents in Three Montana Counties*

 

 

	Mean Distance	Mean Distance                    Absolute
County	For Anglos**	For American Indians**         Difference

 

Big Horn	9.14 miles	15.33 miles	6.19 miles
Blaine	5.31 miles	13.88 miles	8.57 miles
Rosebud	10.13 miles	5.67 miles	4.46 miles

 

*The hypothetical second sites are Little Big Horn College in Big Horn County, Fort Belknap Hospital in Blaine County, and the Northern Cheyenne Tribal Building in Rosebud County.

 

**Two-tailed T tests indicated the differences in the mean distances for Anglos and American Indians were statistically significant at the 0.01 level.

 

SOURCE: Calculated by the University of Alabama Cartographic Research Laboratory using data secured from the Bureau of the Census.

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I declare under penalty of perjury the foregoing is true and correct.  Executed this 23 day of October.  

 

/s/ Gerald R. Webster

Gerald R. Webster