Wolpoff v. Cuomo, 80 N.Y.2d 70 (1992)
When complying with federal mandates in redistricting, the state legislature’s plan will be upheld unless it unduly departs from state constitutional requirements regarding contiguity, compactness, and the integrity of county lines; courts should not substitute their judgment for the legislature’s unless the plan demonstrably violates fundamental law.
Summary
This case addresses a challenge to New York State’s Senate and Assembly redistricting plan, alleging violations of the state constitution due to excessive fragmentation of counties. The Court of Appeals reversed the lower court’s decision, holding that the redistricting plan was constitutional. The Court emphasized the legislature’s responsibility to balance federal requirements (one person, one vote and the Voting Rights Act) with state constitutional mandates (compactness, contiguity, and county integrity). The Court found that the legislature’s plan, despite technical deficiencies, was a good-faith effort to comply with federal law, and that the petitioners failed to overcome the presumption of constitutionality afforded to the redistricting plan.
Facts
Following the 1990 census, the New York State Legislature adopted a redistricting plan for the Senate and Assembly in March 1992, which the Governor signed into law in May 1992. Two lawsuits, Wolpoff v. Cuomo and Dixon v. Cuomo, were filed challenging the plan. The plaintiffs alleged that the Senate redistricting plan unconstitutionally fragmented counties, violating Article III, Section 4 of the New York State Constitution, which requires districts to be compact, contiguous, and respect county lines where possible. The Senate plan divided multiple counties and created bi-county districts for the first time in the state’s history.
Procedural History
In Wolpoff, the Senate Majority Leader had the case removed to federal court, but it was remanded back to state court. The Supreme Court, Bronx County, struck down the Senate redistricting plan. Meanwhile, the Supreme Court, New York County, similarly declared the redistricting plan unconstitutional in Dixon. The Majority Leader appealed the Dixon ruling, and the Assembly Speaker appealed the Wolpoff ruling. The Court of Appeals consolidated the appeals. A three-judge Federal court acknowledged the primacy of the state legislature and judiciary in redistricting matters.
Issue(s)
Whether the redistricting plan unduly departs from the State Constitution’s requirements regarding contiguity, compactness, and integrity of counties in its compliance with Federal mandates, specifically the one-person, one-vote principle and the Voting Rights Act.
Holding
No, because the Legislature made a good-faith effort to balance the competing federal and state constitutional requirements, and the petitioners failed to overcome the strong presumption of constitutionality afforded to the redistricting plan.
Court’s Reasoning
The Court acknowledged that the redistricting plan had technical violations of the State Constitution, specifically regarding county integrity. However, the Court emphasized that strict adherence to county lines was impossible while complying with federal mandates for equal population and protecting minority voting rights. The Court relied on Matter of Orans, 15 NY2d 339, which held that redistricting plans could no longer be based solely upon county lines. The Court stated that “the historic and traditional significance of counties in the districting process should be continued where and as far as possible” (id., at 352).
The Court cited Matter of Schneider v. Rockefeller, 31 NY2d 420, 429, stating that the relevant test is whether the Legislature has