Cohen v. Cuomo, 20 N.Y.3d 196 (2012)
The New York State Constitution grants the Legislature discretion in applying methods to calculate Senate seats during redistricting, provided the chosen methods do not amount to a gross and deliberate violation of the Constitution’s intent.
Summary
Petitioners challenged Chapter 16 of the Laws of 2012, arguing it unconstitutionally expanded the New York State Senate from 62 to 63 districts due to inconsistent application of methods for calculating Senate seats based on population growth. The Legislature used different methods for Queens/Nassau versus Richmond/Suffolk counties when determining full ratios for Senate seat allocation. The Court of Appeals affirmed the lower court’s decision, holding that the Legislature has some flexibility in navigating the complexities of the constitutional formula for Senate readjustment, and the petitioners failed to prove the legislation was unconstitutional beyond a reasonable doubt.
Facts
Following the 2010 census, the New York State Legislature undertook the process of adjusting representation in the State Senate. The process involves determining the number of Senate seats required based on population increases. For counties divided after 1894 (Queens/Nassau) and those combined into a single Senate district (Richmond/Suffolk) in 1894, the Constitution lacks specific guidelines on how to calculate the ratio. The Legislature employed two different calculation methods: “rounding down before combining” and “combining before rounding down.” The Legislature used “rounding down before combining” for Queens and Nassau Counties, and “combining before rounding down” for Richmond and Suffolk Counties. Petitioners argued this manipulation was politically motivated to achieve a 63-seat Senate.
Procedural History
Petitioners commenced a special proceeding in Supreme Court seeking a declaration that Chapter 16 of the Laws of 2012 was unconstitutional. Supreme Court found petitioners failed to meet their burden of proving the redistricting plan unconstitutional. Petitioners appealed directly to the New York Court of Appeals.
Issue(s)
Whether the Legislature’s use of different methods for calculating the number of Senate seats for different parts of the state during redistricting violates Article III, § 4 of the New York State Constitution.
Holding
No, because the Legislature is accorded some flexibility in working out the intricacies of the constitutional formula for readjusting the size of the Senate, and petitioners failed to demonstrate that the use of two constitutionally adequate means of determining the number of Senate seats, in the course of addressing two discrete historical contexts, is unconstitutional.
Court’s Reasoning
The Court emphasized the strong presumption of constitutionality afforded to acts of the Legislature, stating that a redistricting plan will only be deemed unconstitutional if it can be shown beyond a reasonable doubt to conflict with fundamental law. The Court referred to Matter of Wolpoff v Cuomo, 80 NY2d 70, 78 (1992), quoting Matter of Fay, 291 NY 198, 207 (1943), for this standard. The Court acknowledged that it had previously recognized both methods of calculation at issue. Referencing its prior decision in Schneider v. Rockefeller, 31 NY2d 420 (1972), the Court reiterated that the Legislature must be accorded some flexibility in interpreting the “opaque intricacies of the constitutional formula” for adjusting the Senate’s size. The rationale provided by respondents was that Nassau County should be treated as if it existed in 1894, justifying the use of “rounding down before combining” for Nassau and Queens. For Richmond and Suffolk, which existed as a combined district in 1894, the established practice of “combining before rounding down” was continued. The Court concluded that it is not its role to judge the wisdom of the methods employed, but only to determine if they constitute “a gross and deliberate violation of the plain intent of the Constitution and a disregard of its spirit.” Citing Matter of Sherrill v O’Brien, 188 NY 185, 198 (1907). The Court held that petitioners failed to meet the burden of proving the unconstitutionality of the redistricting plan.