Coca and Rangel-Lopez v. City of Dodge City

The UCLA Voting Rights Project (VRP) alongside the American Civil Liberties Union (ACLU) of Kansas and Cleary Gottlieb Steen & Hamilton LLP filed a lawsuit against Dodge City over its at-large election system for the city commission. The case argued that the at-large system violated Section 2 of the Voting Rights Act of 1965, and the Fourteenth Amendment.

The current at-large voting system unlawfully dilutes the voting power of Latino residents. Considering that the Latino population in Dodge City is growing, with Latinos currently making up 65% of the total population, 59% of the Voting Age Population (VAP), and 46% of the Citizen Voting Age Population (CVAP), the at-large system is detrimental to their ability to elect candidates of their choice.

The commission’s at-large system of voting allows for qualified city residents to vote in elections for all five districts. Whereas in a single-member district model, commission members would represent geographic districts within the city and only residents in those districts could vote. Plaintiffs argued that a commission map could be drawn that would enable Latinos the ability to elect candidates of choice in two out of five districts.

The court denied Defendants’ motion to dismiss as well their motion for summary judgement, which allowed for the case to proceed to trial. Trial took place in February 2024.

In July 2024, the district court ruled in favor of Dodge City, rejecting the Plaintiffs’ claims.

 

Legal Documents

Complaint – 12/15/2022

Amended Complaint – 1/03/2023

Defendants’ Motion to Dismiss Plaintiffs’ Amended Complaint – 1/11/2023

Defendants’ Brief ISO Their Motion to Dismiss Plaintiffs’ Amended Complaint – 1/11/2023

Plaintiffs’ Memorandum of Law In Opposition to Motion to Dismiss for Failure to State a Claim – 2/01/2023

Statement of Interest of the United States re Motion to Dismiss – 2/10/2023

Defendants’ Reply ISO Their Motion to Dismiss – 2/15/2023

MOTION for Leave to file A REPLY TO THE STATEMENT OF INTEREST – 2/24/2023

ORDER granting United States’ Motion for Leave to File a RESPONSE (not Reply) to Statement of Interest – 2/24/2023

MOTION for Leave to file Reply to Defendants’ Response to the United States’ Statement of Interest – 2/27/2023

Proposed Plaintiffs’ Reply to Defendants’ Response to the United States’ Statement of Interest – 2/27/2023

Defendants’ Response to the United States’ Statement of Interest – 2/27/2023

Plaintiffs’ Reply to Defendants’ Response to the United States’ Statement of Interest – 2/28/2027

Memorandum and Order re Motion to Dismiss – 4/18/2023

Joint Answer to Amended Complaint for Declaratory and Injunctive Relief – 5/02/2023

Defendants’ Motion to Amend and Certify Order for Interlocutory Appeal and Motion to Stay Proceedings – 5/02/2023

Defendants’ Memorandum ISO Their Motion to Amend an dCertify Order for Interlocutory Appeal and Motion to Stay – 5/02/2023

MOTION REFERRAL to Magistrate Judge REMOVED as to MOTION to Stay Case re Order on Motion to Dismiss – 5/02/2023

Defendants Reply ISO Their Motion to Amend and Certify Order for Interlocutory Appeal and Motion to Stay Proceedings – 5/16/2023

Defendants’ Notice of Supplemental Authority ISO their Motion to Amend and Certify – 5/30/2023

Exhibit list for Defendants’ Notice of Supplemental Authority – 5/30/2023

Plaintiffs’ Notice of Supplemental Authority – 6/09/2023

Exhibit List – 6/09/2023

Exhibit A – Health and Hosp. Corp. of Marion Cnty. v. Talevsk – 6/09/2023

Order re Pretrial Order (Revised PTO) – 8/29/2023

Pretrial Order – 9/15/2023

Defendants’ Motion for Summary Judgment – 9/22/2023

Defendants’ Brief ISO Summary Judgment – 9/22/2023

Exhibits A-J – 9/22/2023

Index to MSJ Exhibits – 9/22/2023

Plaintiffs’ Memorandum of Law in Opp to Defendants’ Motion for Summary Judgment – 10/13/2023

Exhibit List and Exhibits – 10/13/2023

Defendants’ Reply ISO Their Summary Judgment Motion – 10/27/2023

Exhibit K (Supplemental Declaration of Nickolaus J. Hernandez) – 10/27/2023

Exhibit K-1 (Sample Nov. 2021 Election Ballot) – 10/27/2023

Exhibit K-2 (Results for 2019 Dodge City Commission Gen’l Election) – 10/27/2023

Index of Exhibits – 10/27/2023

MEMORANDUM AND ORDER denying Motion for Summary Judgment – 12/13/2023

Trial Scheduling Order – 1/05/2024

STIPULATION of Facts and Exhibits by Miguel Coca, Alejandro Rangel-Lopez. (Ching, Kunyu) – 2/14/2024

MOTION for Order to Drop Individual Defendants and the Dodge City Commission by Defendants – 2/14/2024

TRIAL BRIEF by Miguel Coca, Alejandro Rangel-Lopez – 2/20/2024

Defendants’ Trial Brief – 2/20/2024

RESPONSE by Plaintiffs Miguel Coca, Alejandro Rangel-Lopez re Motion to Dismiss Party – 2/21/2024

MEMORANDUM AND ORDER granting MOTION for Order to Drop Individual Defendants – 2/23/2024

Defts TRIAL BRIEF Bench Brief Regarding Inadmissibility of Proposed Exhibits – 2/25/2024

Doc 189 Defts TRIAL BRIEF Bench Brief Regarding RPV Near Me – 2/25/2024

Doc 189-1 Defts TRIAL BRIEF Bench Brief Regarding RPV Near Me – 2/25/2024

Doc 189-2 Defts TRIAL BRIEF Bench Brief Regarding RPV Near Me – 2/25/2024

Doc 190 Plntffs TRIAL BRIEF in Response to Defendant’s Trial Brief Regarding Exhibits 41, 143, 144 – 2/25/2024

Doc 192 Plaintiffs’ Response to Defendant’s Bench Brief re Exhibit 136 – 2/26/2024

Doc 195 Defendants’ Motion for Judgment on Partial Findings – 2/28/2024

Doc 200 Order granting in part and denying in part Motion for Judgment on Partial Findings – 2/29/2024

Doc 211 Plaintiffs’ Proposed Findings of Fact and Conclusions of Law – 3/22/2024

Doc 212 Defendants’ Proposed Findings of Fact and Conclusions of Law – 3/22/2024

Doc 214 Dodge City’s Response to Plaintiffs’ Proposed Findings of Facts and Conclusions of Law – 4/05/2024

Doc 215 Plaintiffs’ Response to Defendant’s Proposed Findings of Fact and Conclusions of Law – 4/05/2024

Doc 216 – Memorandum and Order – Dodge City Decision – 7/10/2024

Doc 217 Judgement in favor of Defts – 7/10/2024

 

 

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Navajo Nation, et al. v. San Juan County, NM et al.

The UCLA Voting Rights Project, in partnership with the Lawyers Committee for Civil Rights Under the Law, the ACLU of New Mexico, DLA Piper and the Navajo Nation Department of Justice filed a complaint against San Juan County, New Mexico and their Board of Commissioners over their newly adopted legislative map that effectively dilutes the vote of the Indigenous population within the county.

Indigenous persons in San Juan County, largely Navajo Nation citizens, constitute the largest racial or ethnic group in the County. Despite this, the new legislative map, adopted over the objections of the Navajo Nation among others, unlawfully distributes the population in such a way that Indigenous persons only have the opportunity to elect their candidate of choice in one of the five total districts in the County. The plaintiffs asked the court to block the 2021 redistricting plan.

On February 28, 2024, a settlement was reached with San Juan County in which a new map was adopted that allowed for more equitable representation for American Indian voters in the County. In March 2024, the settlement was accepted by a federal judge and the case was dismissed.

Legal Documents
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League of United Latin American Citizens (LULAC) et al. v. Abbott

Published November 19, 2025

On October 6, 2025, the UCLA Voting Rights Project (VRP), directed by Dr. Matt A. Barreto and Chad W. Dunn, JD, in the Luskin School of Public Affairs, successfully argued in favor of Hispanic and Black voters in League of United Latin American Citizens (LULAC) et al. v. Abbott,

VPR’s legal director, Dunn, and senior staff attorney, Sonni Waknin, represented Hispanic and Black voters across Texas, alleging that the congressional map was intentionally discriminatory and drawn to dismantle existing Hispanic opportunity districts in Dallas-Fort Worth, Houston, Central Texas, and the Gulf Coast area, and Black voters in the Dallas-Fort Worth and Houston areas.

VRP’s faculty director, Dr. Barreto, testified as an expert witness on behalf of the Brooks and MALC plaintiffs and individual voters, teaming up with VRP senior data scientist Michael Rios to author two expert reports and a rebuttal report submitted as evidence to the Court. The Barreto and Rios reports provided critical statistical evidence that the 2025 Texas congressional map used racial targets when drawing district boundaries and the Federal Court credited the Barreto-Rios reports as credible and relied on their data analysis in striking down the Texas map.

The decision marks a victory for voting rights advocates who have argued the map was drawn “focusing on race,” fragmenting and concentrating underrepresented communities to weaken their political influence. In doing so, the Court found that the Texas legislature and government acted with intentional discrimination against Black and Hispanic voters.

The 2025 map attempted to dismantle four majority-minority districts that elect Hispanic and Black members of Congress, and the Federal Court has ruled that it was unconstitutional.

Contributors: Chad Dunn, Matt Barreto, Sonni Waknin, Michael Rios

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Portugal et al. v. Franklin County

The UCLA Voting Rights Project (VRP), successfully represented three individual Latino voters and the League of United Latino America Citizens (LULAC) in challenging Franklin County’s use of the at-large method of election for County Commissioner seats under the Washington Voting Rights Act (WVRA).

The UCLA VRP sent a notice letter under the WVRA in October 2020 and filed a lawsuit in April 2021. The plaintiffs argued that Latinos have never elected a candidate of choice to the Franklin County Commission under the at-large system due to racially polarized voting in combination with other factors. After a year of litigation, Franklin County settled the lawsuit.

Under the settlement, Franklin County Commissioner elections will now operate under single-member districts. After the settlement, an intervenor in the case filed a petition with the Washington Supreme Court to have the Washington Voting Rights Act declared unconstitutional. The UCLA VRP, representing the Plaintiffs, supported the WVRA’s constitutionality before the Washington Supreme Court. The Washington Supreme Court ruled that the WVRA was constitutional. The United States Supreme Court denied review.

Contributors: Sonni Waknin, Chad Dunn, Vivian Alejandre, Michael Rios & Tye Rush


Trial Court Documents

Conformed Amended Complaint for Injunctive Relief Under the WVRA- 5/5/2021

Defendants’ Answer to Complaint for Injunctive Relief Under the Washington Voting Rights Act- 5/12/2021

Plfs’ Second Motion for Partial MSJ Exhibits- 3/21/2022

Plfs’ Second Motion for Partial Summary Judgment- 3/21/2022

Order Approving Settlement – conformed – 5/09/2022


Washington Supreme Court

Opening Brief – 7/28/2022

Brief of Respondents- 9/12/2022

Reply Brief of Appellant- 12/22/2022

Brief of Amicus Curiae Brennan Ctr for Justice ISO Plaintiffs-Respondents- 3/27/2023

Brief of Law School Clinics Focused on Civil Rights as Amici Curiae- 3/27/2023

Amicus Brief of State of Washington- 4/03/2023

OneAmerica and CLC Amici Curiae Brief- 4/03/2023

Slip Opinion- 6/15/2024


U.S. Supreme Court

Gimenez Petition Final- 11/07/2023

Gimenez PFC Appendix- 11/07/2023

Portugal Respondents’ Waiver of Right to Respond- 11/28/2023

Amicus Brief Project on Fair Representation- 12/13/2023

Court Letter Requiring Response from Portugal Respondents- 12/28/2023

Respondents Letter Requesting Extension to File Response- 1/12/2024

Brief in Opposition Final- 2/28/2024

Gimenez Reply Brief Final- 3/13/2024

SCOTUS Letter Denying Gimenez Writ of Certiorari- 4/01/2024

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Amicus Brief, Merrill et.al., v. Milligan et.al.

Published July 18, 2022

On July 18, 2022, UCLA Voting Rights Project (VRP) filed an amicus brief on behalf of UCLA Social Scientists with the U.S. Supreme Court in the voting rights case Merrill et. al., v. Milligan et. al. The VRP argued for the Court to keep the Voting Rights Act’s longstanding protections of minority voting rights intact.

The VRP’s amicus brief focused on three main points. First, that race still plays a significant role in elections. VRP cites social science articles regarding racially polarized voting analysis and the role it plays in demonstrating racial bias and animus in voting. In this section VRP notes the link racial bias has to the supposedly race neutral redistricting factor of partisanship. Second, VRP argues that VRA section 2b (specifically the Gingles standards laid out by the Supreme Court in Thornburg v. Gingles) protections remain necessary to protect voters in local governments. To support, VRP highlights the persistence of at-large voting systems in local elections (school boards, city councils, etc). VRP also discusses the exacting standards imposed by Gingles that already make a successful Section 2 violation difficult for plaintiffs to prove.  Lastly, VRP argues that non-discriminatory voting systems benefit minority groups, emphasizing the link between racial bias and policy outcomes for minority communities. VRP cites social science highlighting the stark difference in policy outcomes when there is significant minority representation versus when there is not.

Background of Merrill et.al., v. Milligan et.al: Three separate sets of Plaintiffs challenged Alabama’s 2021 congressional district maps alleging constitutional and VRA violations. Specifically, Plaintiffs alleged that the black community was “packed” into Congressional District 7, “cracking” the remaining black community among other districts. This prevented the drawing of a second majority black district in the state in violation of the VRA. After a three-judge district court issued an injunction on the Alabama’s map and ordered the drawing of a new map, the Supreme Court granted Alabama’s request for a stay.

Contributors: Bernadette Reyes, Sonni Waknin, Chad Dunn, Matt Baretto

Read the amicus brief here:
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Pettaway v. Galveston County, Texas

A federal judge found that Galveston County’s 2021 redistricting plan diluted the voting strength of Black and Latino voters, violating Section 2 of the Voting Rights Act.

The UCLA Voting Rights Project (UCLA VRP), along with co-counsels Neil G. Baron and the Campaign Legal Center, representing three Galveston residents, the Honorable Terry Petteway, Honorable Penny Pope and Honorable Derrick Rose, filed the challenge to Galveston County’s 2021 redistricting plans claiming that they were racially discriminatory in intent and impact. The U.S. Department of Justice and local chapters of NAACP and LULAC filed parallel litigation, which was consolidated into the current case. This suit followed a prior lawsuit filed in 2013 by Petteway, Pope and Rose challenging Galveston County’s Justice of the Peace and Constable districts.

Read the Court Order here and the Findings of Facts here.

“Today’s decision recognizes and rectifies the discrimination and dilution of the voting strength of Black and Latino voters in Galveston County,” said Chad Dunn, Legal Director of UCLA VRP. “The court’s ruling underscores the fundamental principle that every citizen, regardless of race or background, deserves an equal opportunity to elect candidates of their choice in countywide offices. The decision also reaffirms the enduring power and relevance of the Voting Rights Act. It serves as a reminder that attempts to undermine the voices of minority communities, as witnessed in the 2021 redistricting in the county, will not go unchallenged or unnoticed.

Bernadette Reyes, counsel in the case and voting right counsel at UCLA VRP, added, “The implications of this decision extend beyond the borders of Galveston County. The ruling sends a clear message to jurisdictions nationwide: Redistricting efforts that marginalize minority communities, whether out of malice or negligence, violate the fundamental pillars of our democracy and will not be tolerated. UCLA VRP remains committed to ensuring that the letter of this ruling is fully implemented until Galveston County’s redistricting reflects the rich diversity and strength of its communities.”

UCLA Voting Rights Project is an advocacy project housed within the UCLA Luskin School of Public Affairs.

Contributors: Bernadette Reyes & Sonni Waknin

Plaintiffs’ Motion to File Supplemental Complaint- January 2018

Proposed First Amended Complaint – March 2022

Court Order – October 2023

FOCOLS from Court – October 2023

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