NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE v. UNITED STATES POSTAL SERVICE et al

Filing 8

MOTION for Preliminary Injunction by NATIONAL ASSOCIATION FOR THE ADVANCEMENT OF COLORED PEOPLE (Attachments: #1 Memorandum in Support, #2 Declaration Declaration of Carmen Watkins, #3 Declaration Declaration of Earl Graham, #4 Text of Proposed Order, #5 Certificate of Service)(Zieve, Allison)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

NATIONAL ASSOCIATION FOR THE
ADVANCEMENT OF COLORED
PEOPLE,
Plaintiff,
v.
UNITED STATES POSTAL SERVICE,
et al.,
Defendants.

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) Civil Action No. 20-cv-2295 (TSC)
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DECLARATION OF CARMEN WATKINS
I, Carmen Watkins, declare as follows:
1.

I am the Interim Vice President of Field Operations for the National Association

for the Advancement of Colored People (NAACP). In that Position, I am a member of the Senior
Leadership of the Organization and involved in decisions about the NAACP’s strategic priorities.
2.

Founded in 1909, the NAACP is the nation’s largest and oldest civil rights

grassroots organization. The NAACP works to ensure the political, educational, social, and
economic equality of all persons and to eliminate race-based discrimination. The NAACP has
fought in the courts for decades to protect the constitutional guarantee of equal protection under
law. To advance its mission, the NAACP has brought landmark civil rights cases over its 109-year
history and continues to do so. The NAACP also has filed numerous amicus briefs in cases that
significantly impact people of color.
3.

The NAACP is organized into state and local units, known as conferences, chapters

and branches, all of which are part of the NAACP. Every member of a state or local unit is also a

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member of the NAACP. The NAACP has conferences, chapters, or branches in 48 states, and it
has over 200,000 members nationwide.
4.

In my position as Interim Vice President of Field Operations and a member of the

Senior Leadership team, I regularly communicate with NAACP members and volunteers
throughout the country.
5.

The NAACP relies on mail service by the United States Postal Service for a variety

of important purposes, including communicating with members. NAACP members also rely on
the United States Postal Service, including to receive medications, pay bills, receive NAACP
material, send and receive mail-in ballots, and other purposes. Delays in mail delivery are of
significant concern to the NAACP and to NAACP members.
6.

The NAACP has established a civic engagement program, which is designed to

encourage citizens to be fully engaged in the democratic process, and to raise awareness for
political, educational, social, and economic equality for communities of color in the electoral and
legislative process. Drawing upon the resources of our branches across the country, the program
seeks to increase turnout among Black voters in federal, state, and local elections.
7.

The widespread delays in USPS service over the last month have required the

NAACP, and will continue to require the NAACP, to divert resources that it would have otherwise
expended on other aspects of its civic engagement program.
8.

For example, because of numerous reports over the past month about the reliability

and timeliness of mail delivery, the Florida State Conference of the NAACP and volunteers it
recruited as part of the civic engagement program disseminated information and organized
transportation for voters to drop off their absentee ballots at local supervisors of elections in
advance of Florida’s August 18, 2020 primary election, including after church services. The

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Florida State Conference is planning to conduct similar activities in preparation for the November
2020 election as a result of continuing concerns about delays in mail services.
9.

Due to concerns about delays in mail delivery, the Georgia State Conference of the

NAACP also plans to conduct similar activities in preparation for the November 2020 election,
including organizing events and transportation for voters to drop off their absentee ballots at drop
boxes.
10.

Likewise, due to concerns about delays in mail delivery, the Ohio State Conference

of the NAACP is planning to disseminate information and organize transportation for voters to
drop off their absentee ballots at local supervisors of elections after church services, in connection
with the November 2020 election.
11.

Engaging in these activities has diverted resources from the regular activities of the

NAACP’s civic engagement program. Absent the increasing mail delays this summer, the Florida,
Georgia, and Ohio State Conferences would instead devote the resources spent on these activities
to the regular activities of the NAACP’s civic engagement program, such as registering voters,
contacting registered voters to ensure they have accurate voting information and encouraging them
to vote, organizing events to get out the vote, and conducting voter protection activities during
early voting.
12.

Concerning voter protection activities, for example, the Florida State Conference

plans to have its members and volunteers recruited as part of the civic engagement program
conduct in-person and remote poll monitoring for the 2020 November election. Because of the
mail delays, however, they will instead have fewer members and volunteers to conduct poll
monitoring because they will need to send those members and volunteers to assist with

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