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12 I .a4i;�'. 5.. '"i�'}"ti•..' rd'�Y4...a'°�S= ��,t��,,"". �s.....�.P1.av'�_., ,;. m.. ° , f.c_, �,rti �;,;,;- .., 28905 Wight Road ' x�h�.�'"°�c�-�.„x :�4>r at�-•:'...:«::a��' .,,iYt s%c:.. 'z'a:ew ta 'a6&1�1��5'k ';�-� Malibu,California rnia 90265 (3!0)457-0970 Qv'".+. ;'!a •aw`?�'�:Fy, .1.tNra.a `:'.'�• '`''tcW :';.sr?.:",a''+9' ,. ',.: ,x �u '� < �rxS:'�sa=;s,.;. .. ;•;moi 4.?��:+�`.r.:-:`''.;r-Y x_ M' _ s .>-1� �t1Tiu. 1[E�II'S.CiI!'iF VIA CERTIFIED MAIL August 2, 2021 Karen Diaz, City Clerk City of Pleasanton 123 Main Street P.O. Box 520 Pleasanton, CA 94566 Re: Violation of California Voting Rights Act I write on behalf of our client, Southwest Voter Registration Education Project and its members residing within the City of Pleasanton ("Pleasanton" or "City"). Pleasanton relies upon an at-large election system for electing candidates to its governing board. Moreover, voting within the City is racially polarized, resulting in minority vote dilution, and, therefore, the City's at-large elections violate the California Voting Rights Act of 2001 ("CVRA"). The CVRA disfavors the use of so-called "at-large" voting— an election method that permits voters of an entire jurisdiction to elect candidates to each open seat. See generally Sanchez v. City of Modesto (2006) 145 Cal.App.4. 660, 667 ("Sanchez"). For example, if the U.S. Congress were elected through a nationwide at-large election, rather than through typical single-member districts, each voter could cast up to 435 votes and vote for any candidate in the country, not just the bare candidates in the voter's district, and the 435 candidates receiving the most nationwide votes would be elected. At-large elections thus allow a majority of voters to control every seat, not just the seats in a particular district or a proportional majority of seats. Voting rights advocates have targeted "at-large" election schemes for decades, because they often result in "vote dilution," or the impairment of minority groups' ability to elect their preferred candidates or influence the outcome of elections, which occurs when the electorate votes in a racially polarized manner. See Thornburg v. Gingles, 478 U.S. 30, 46 (1986) ("Gingles"). The U.S. Supreme Court "has long recognized that multi-member districts and at-large voting schemes may operate to minimize or cancel out the voting strength" of minorities. Id. at 47; see also id. at 48, fn. 14 (at-large elections may also cause elected