51 N.Y.2d 717 (1980)

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Strict compliance with the content requirements of Election Law § 6-134(2) is mandatory for designating petitions, specifically regarding the inclusion of candidate names and addresses on the cover sheet; substantial compliance only applies to form, not prescribed content.

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Summary

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This case addresses the validity of a designating petition for a county committee election where the petition’s cover sheet omitted the names and addresses of the candidates. The New York Court of Appeals held that the omission constituted a fatal defect because it violated the strict compliance standard for matters of content under Election Law § 6-134(2). The court emphasized that while substantial compliance suffices for form-related details, the statute’s explicit content mandates must be rigidly followed. The order of the Appellate Division was reversed and the case remitted for factual determinations, if any.

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Facts

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The original cover sheet of a designating petition failed to include the names and addresses of candidates for election as members of the county committee. Additionally, there was no cover sheet indicating the names and addresses of candidates for election as district leaders. The cover sheets for judicial delegate candidates were filed 15 minutes late.

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Procedural History

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The Appellate Division reversed the lower court’s decision