d.
Some Native voters do not have licenses to drive off-reservation. 09/08/20
Trial Tr.
(Perez) at72:7-12.
e.
Voter costs were defrned by expert testimony at trial as socioeconomic barriers that
could prevent an individual from casting their ballot.
f.
Poverty is a voter cost resulting in lower tumout by low income individuals.
09109/20 Trial
Tr. (McCool) at 351:10-21; see also 09/08/20 Trial Tr. (Street) at
2ll:5-212:3.
g.
Lack of childcare options on reservations is also a voter cost faced by some Native
voters. 09/08/20 Trial Tr. (Perez) at 74:11-23.
h.
Many Native Americans living on rural reservations without home mail access have
difficulties accessing their P.O. box due to distance, socioeconomic conditions, and
lack of reliable transportation. 09/08/20 Trial Tr. (Cuts the Rope) at 1 20: 1 5- 1 25 : 1 1 ;
see Pl.
i.
Ex. I l3,lTlT 13, 37, 65-69/Stip. Ex. 2.
Testimony at trial established that vehicles on reservations
in
Montana are
sometimes scarce and often shared. A single vehicle is sometimes responsible for
getting everyone in a household to and from work, to all social engagements,
doctor's office visits, as well as any mail runs or ballot drop offs. 09108/20
Tial
Tr. (Cuts the Rope) at 123:9-125:11;126:10-127:20;09/09120 Trial Tr. (McCool)
ar 332:16-333:14; Pl Ex. 113,
not be in good repair or "road
fl 12lstip. Ex.2. Additionally, these vehicles may
legal;'
73:14-22.
16
09108120
Trial Tr. (Perez) at 71:17-72:12;