November 15, 2018

National Association for the Advancement of Colored People
Registered Agent
National Corporate Research, LTD.
10 East 40th Street 10th Floor
New York, New York 10016
NAACP National Headquarters
General Counsel
4805 Mt. Hope Drive
Baltimore, MD 21215
NAACP Houston Branch
Yolanda Smith
2002 Wheeler St.
Houston, Texas 77004
Re:

Appeal for New Election

To Whom It May Concern,
This letter is to serve as an appeal for a new election pursuant to Article IX, Section 2(o)
of the Bylaws for Units of the NAACP. Attached you will find a petition with a minimum of 50
signatures as required.
Please note that I, and the members I represent, want nothing more than to bridge the
divide that has appeared, and dispel the cloud that currently sits over the NAACP. Our number
one goal before anything else is to aid in the rehabilitation of the NAACP. However, to make
this a reality we must make it known that dissention should never be the problem, but corruption
and lack of transparency should always trouble us. It is our sincerest hope and wish that
Headquarters take corrective action in a just and equitable manner befitting national leadership.
“The only thing necessary for the triumph of evil is for good men to do nothing.”
-Edmund Burke
Our grievances are as follows:
a. Numerous challenge ballots were not placed in envelopes but instead put directly into
the ballot box.
b. There were 3 different “rolls” none of which we had the opportunity to review. We
have no way of knowing the legitimacy of any of the memberships despite our having

4101 Greenbriar Drive, Suite 210   Houston, Texas 77098   Office: 832.371.6339   Fax: 713.528.3415  

 had asked National Headquarters and the Branch about the membership rolls and their
creation on October 28th 2018. Please see the attached email.
c. There were a minimum of 75 persons who were not on the membership rolls but were
“verified” through “alternate means”, which were not shared with Watchers.
d. Of two individuals running for office, Claude Cummings Jr. and Bishop James
Dixon, one or both “purchased” at least 200 blank memberships not attributed to any
individual on October 16th 2018. On election day, November 15th 2018, the same
individual(s) bussed individuals in to vote (presumably for their slate). These
individuals then created or renewed memberships and backdated them to the pre paid
blank memberships previously “purchased”. Other individuals were found on one of
the fraudulent rolls, many of which showed a membership start date of October 15th
2018.
i. Please note that the NAACP Constitution states:
NAACP Constitution - ARTICLE IV (1). “Any person in accord with the principles and policies
of the Association may become a member with the consent of the Board of Directors. Such
person shall become a member by agreeing to abide by the rules and policies of the Association
and the decisions of the Board of Constitution of the NAACP Directors and by paying in advance
the annual membership fee established by the Board of Directors.”
ii. The Bylaws for Units of the NAACP states:
NAACP Bylaws ARTICLE IX (2)(k). “….For all other purposes, a member in good standing is
one who has paid the requisite minimum membership fee to the branch at least (30) thirty days
prior to the date the election is held or the nominating petition is filed. For all other purposes, a
member in good standing is one who has paid the requisite minimum membership fee to the
branch.”
iii. While not on point please consider this portion of the Bylaws for
guidance:
NAACP Bylaws ARTICLE IX (1)(d). “…For the purpose of signing a nomination petition, a
member in good standing is one whose name appears on the roll of a Unit in good standing
within the State/State-Area Conference at least thirty (30) days prior to the date the nominating
petition is filed.”
e. A person is defined as, “a human being regarded as an individual”. From this
definition we can see that the NAACP Constitution speaks to a person (or individual)
becoming a member, “by agreeing to abide by the rules and policies of the
Association and the decisions of the Board of Constitution of the NAACP Directors
and by paying in advance the annual membership fee established by the Board of
Directors.” The Constitution has not made an allowance for someone or some
organization to purchase multiple memberships that are not assigned to a person.
This is further evidenced by the fact the second requirement to be a member is,
“…agreeing to abide by the rules and policies of the Association and the decisions of
the Board of Constitution of the NAACP Directors…”. In short, a person may

4101 Greenbriar Drive, Suite 210   Houston, Texas 77098   Office: 832.371.6339   Fax: 713.528.3415  

 become a member by 1) purchasing a membership and 2) agreeing to rules and
regulations.
f. Now that we are aware what constitutes a member we can turn our attention to the
Bylaws ARTICLE IX (2)(k). It states the one (an individual) is a member in good
standing if they pay the requisite fee to the branch. It is imperative that we recognize
that the Bylaws specify one.
g. For further guidance I have included Bylaws ARTICLE IX (1)(d). While it speaks to
the purpose of signing a nomination petition, it is instructive because it uses the same
language of “one” with the additional language of “whose name appears on the roll
of a Unit…”. This gives us insight as to the correct interpretation of any vague
bylaws or constitutional entries.
h. Also, regarding letter “d” above, when the watchers and other interested parties asked
for verification of payment, membership forms, bank statements showing the
payments, dated receipts or any other veritable items. We were summarily denied.
Our requested remedies are as follows:
a. The complete invalidation of the election results of November 15, 2018.
b. The removal of Bishop James Dixon and Claude Cummings Jr. as candidates.
c. The setting of a new election date to be decided by Headquarters, Lloyd C.
Ford, and Dr. James Douglas.
d. For the new election to be ran solely by Headquarters and the Missouri City
Branch of the NAACP.
e. The review and agreement of a membership roll by Headquarters, Lloyd C.
Ford II, and Dr. James Douglas. Each Candidate for President may have one
advisor.
f. Each Candidate for President will be allowed a copy of the agreed upon
membership roll.
g. The setting of one or more townhall debates for members to ask questions of
the President and 1st Vice President candidates. Time, date, and location to be
decided by Headquarters, Lloyd C. Ford II, and Dr. James Douglas.
For your reference the election supervisory committee and poll watchers were as follows:
1.
2.
3.
4.
5.
6.
7.

Roger Harris
Desmond Watley-Calloway
Astoria Stubbs
Linda Nwoke
Porchia Harris
Chris Darkins
Jahmes Bonner

4101 Greenbriar Drive, Suite 210   Houston, Texas 77098   Office: 832.371.6339   Fax: 713.528.3415  

 Sincerely,
TITUS & MILLS PLLC

By: Eddison S Titus,
For the Firm
EST/EST
Certified Mail Number:
Return Receipt Requested

4101 Greenbriar Drive, Suite 210   Houston, Texas 77098   Office: 832.371.6339   Fax: 713.528.3415