LaRoque v. Holder: Plaintiff’s Reply Brief in Support of Its Motion to Convene a Three-Judge Panel

Plaintiffs seek declaratory and injunctive relief challenging the constitutionality of Section 5 of the Voting Rights Act of 1965, as amended in 2006 (hereinafter “Section 5”). Complaint ¶¶ 1-7, 11-37. Pursuant to 28 U.S.C. §§ 291(b), 2284 and 42 U.S.C. § 1973c(a), as well as the Court’s Local Rule 9.1, Plaintiffs apply for a three-judge court to adjudicate this action. In support of this application, Plaintiffs respectfully submit the following memorandum of points and authorities.