Franklin v. Krause, 28 N.Y.2d 367 (1971)
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A county legislature apportionment plan is constitutional if it makes a good-faith effort to achieve equality of representation based on population while respecting the integrity of political subdivisions and historical boundaries, and multi-member districts are permissible unless they systematically dilute the voting strength of a racial or political element.
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Summary
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This case concerns the constitutionality of an apportionment plan for the Rockland County Legislature. The plaintiffs challenged the plan, arguing it failed to achieve equality of representation and that the use of multi-member districts was inherently defective. The New York Court of Appeals upheld the plan, finding that it represented a good-faith effort to balance population equality with the practical considerations of maintaining existing town boundaries. The court also found no evidence that the multi-member districts diluted the voting strength of any particular group.
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Facts
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Rockland County’s Board of Supervisors was previously deemed malapportioned by a Federal District Court. After voters rejected three proposed reapportionment plans, a lawsuit was filed compelling reapportionment. The Board then submitted a weighted voting scheme which was rejected. The Board then devised a plan for a County Legislature composed of 18 members from 5 districts corresponding to the county’s towns. The number of legislators per district was based on population relative to the smallest district (Stony Point). Each representative was to be elected at large within their district, creating multi-member districts (except for Stony Point).
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Procedural History
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The Special Term approved the apportionment plan but modified a provision regarding Town Supervisors automatically becoming County Legislators. The Appellate Division affirmed the Special Term’s determination. This appeal followed to the New York Court of Appeals.
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Issue(s)
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1. Whether the Rockland County apportionment plan is unconstitutional due to population variances among the districts.
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2. Whether the use of multi-member districts in the apportionment plan is inherently defective.
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Holding
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1. No, because the plan represents a good-faith effort to achieve population equality while respecting the integrity of existing town governments and historical boundaries.
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2. No, because multi-member districts are permissible as long as each voter’s vote is approximately equal in weight to that of any other citizen and there is no evidence that the districts were designed to minimize the voting strength of any racial or political element.
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Court’s Reasoning
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The Court recognized that the “one man-one vote” principle applies to local legislative bodies. However, it emphasized that mathematical exactness is not a workable constitutional requirement, quoting Reynolds v. Sims, 377 U.S. 533 (1964): “Mathematical exactness or precision is hardly a workable constitutional requirement.” The Court noted a hierarchy in applying the one person, one vote principle stating that