IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA
STATE OF SOUTH CAROLINAc/o Attorney General ALAN WILSONRembert Dennis Building, Room 5191000 Assembly StreetColumbia, South Carolina 29201,Plaintiff,Civil Action File No. _______Three-Judge Panelv.UNITED STATES OF AMERICA; and ERIC H.HOLDER, JR., in his official capacity as AttorneyGeneral of the United States,Defendants.
COMPLAINT FOR DECLARATORY JUDGMENT
COMES NOW THE STATE OF SOUTH CAROLINA and, pursuant to Section 5 of theVoting Rights Act, 42 U.S.C. Section 1973c (hereinafter, “Section 5 of the VRA”) seeks
adeclaratory judgment that voting-related changes enacted by the South Carolina GeneralAssembly and signed into law by Governor Haley, as provided in Sections 4, 5, 7 and 8 of ActR54 (A27 H3003) (2011), are entitled to preclearance under Section 5 of the VRA. The changeshave neither the purpose nor will they have the effect of denying or abridging the right to vote onaccount of race, color, or membership in a language minority.Further, enforcement of the voter photo identification requirements provided in Section 5 of Act R54 will not disenfranchise any potential South Carolina voter. Indeed, Section 5 of ActR54 is not materially distinguishable from the Indiana voter identification law whose facial