Seaman v. Fedourich, 16 N.Y.2d 94 (1965)
The principle of “one person, one vote,” derived from the Equal Protection Clause, applies to elective legislative bodies at the municipal level, requiring substantial equality of population among districts.
Summary
This case concerns the constitutionality of a districting plan for the Common Council of Binghamton, NY. Plaintiffs challenged the existing plan and a subsequent revision, arguing they violated the Equal Protection Clauses of the U.S. and New York Constitutions. The Court of Appeals affirmed the lower court’s decision, holding that the revised plan failed to meet constitutional requirements because it did not ensure substantial equality of population among the districts. The court emphasized that the “one person, one vote” principle applies to municipal legislative bodies and that the latest official census should be used to determine population for districting purposes.
Facts
The City of Binghamton’s Common Council consisted of 13 members, each elected from one of the city’s 13 wards. The 1960 census revealed a significant disparity in population among the wards, ranging from 542 to 11,426 residents. After a court challenge, the Council proposed a new plan (Local Law No. 1 of 1965) to reduce the Council to 7 members elected from 7 new districts, formed by combining existing wards. Even under this new plan, substantial population disparities persisted, ranging from 7,863 to 15,808 residents per district, according to the 1960 census. The Council attempted to justify the plan by using updated population estimates and excluding patients at a state hospital from the population count of one district.
Procedural History
Residents and voters of Binghamton sued the Common Council, alleging the districting plan violated equal protection. The trial court granted summary judgment to the plaintiffs, finding the existing scheme unconstitutional. After the Council enacted Local Law No. 1 of 1965, the plaintiffs again challenged it. The trial court found the new plan also unconstitutional. The Appellate Division affirmed. The Court of Appeals granted leave to appeal.
Issue(s)
1. Whether the principle of “one person, one vote” applies to elective legislative bodies at the municipal level.
2. Whether Binghamton’s Local Law No. 1 of 1965, creating a new districting plan for the Common Council, met constitutional requirements of equal protection.
3. Whether the city could use its own population estimates instead of the latest federal census data for districting purposes.
4. Whether the city could exclude patients at a state hospital from the population count for districting purposes.
Holding
1. Yes, because the Equal Protection Clause requires that a person has a substantial right to be heard and to participate through elected representatives in the business of government on an equal basis with all other individuals, regardless of whether that government is at the state or municipal level.
2. No, because the plan did not provide substantial equality of population among the districts, entailing more than a minor deviation from the “one person, one vote” principle.
3. No, because the state has mandated that the latest federal census be used to determine population for districting purposes.
4. No, because excluding the patients from the districting plan without investigating relevant factors like prior residence and voting history was arbitrary and discriminatory.
Court’s Reasoning
The court reasoned that the “one person, one vote” principle, established in prior Supreme Court cases regarding state legislative apportionment, extends to municipal legislative bodies. Local governmental units derive their powers from the state, and if the state must adhere to population-based representation, then so must the municipalities to which it delegates power. The court stated: “[I]f, as seems evident, the thrust of the Supreme Court’s decisions is that it is inherent within the concept of ‘equal protection’ that a person has a substantial right to be heard and to participate, through his elected representatives, in the business of government on an equal basis with all other individuals, no reason or justification exists for differentiating, so far as that right is concerned, between the general governmental business carried on in the highest legislative organs of the State and that conducted, by virtue of a delegation of authority, in municipal law-making bodies.”
The court found that Local Law No. 1 failed to achieve substantial equality of population among the districts. Even using the city’s own updated population figures, significant discrepancies existed. The court emphasized that the “overriding objective” of any districting plan “must be substantial equality of population among the various districts, so that the vote of any citizen is approximately equal in weight to that of any other citizen.” The court noted that the relatively small population and compact geographic area of Binghamton made it feasible to create a districting plan that more closely approximated equality of representation.
The court also rejected the city’s use of its own population estimates instead of the latest federal census. It cited the state constitution and various statutes that mandate the use of the federal census for determining population. “[T]he declared policy is readily apparent and reason dictates that the most recent official census be employed in this area as well. Reliance upon such a source will assure periodic, impartial population data on the basis of which an apportionment or districting plan may be initially developed and thereafter regularly revised.”
Finally, the court held that excluding patients at the state hospital from the population count was arbitrary and discriminatory. The court noted that many of the patients were from the Binghamton area, voluntarily admitted, and entitled to vote. The court cited Davis v. Mann, drawing an analogy to the improper exclusion of military personnel. To treat these patients as if they did not exist is to depart, improperly, from the concept of population-based legislative representation.