Matter of Harfenist v. Suffolk County Board of Elections, 67 N.Y.2d 144 (1986)
An objector to a nominating petition for a party position must be a voter enrolled to vote for that specific party position in the same election district as the challenged candidate to have standing to bring the challenge.
Summary
This case addresses the standing requirements for challenging nominating petitions for Conservative Party committee positions. Petitioners, residing in the same Assembly District but different election districts as most of the challenged candidates, sought to invalidate the nominating petitions. The Court of Appeals affirmed the lower courts’ dismissal of the petitions, holding that Election Law § 6-154(2) limits standing to voters enrolled to vote for the specific party position in question. The court emphasized that any change to this standing requirement must come from the legislature.
Facts
Petitioners challenged the nominating petitions designating respondents as candidates for Conservative Party Committee-persons in Chautauqua County.
The petitioner objectors resided in the same Assembly District as the 246 challenged candidates, but only in the same election district as two of them.
Procedural History
Supreme Court dismissed the petitions for lack of standing.
The Appellate Division affirmed the Supreme Court’s decision.
The New York Court of Appeals granted leave to appeal and affirmed the Appellate Division’s order.
Issue(s)
Whether petitioners, who reside in the same Assembly District but not the same election district as the majority of challenged candidates, have standing to challenge the nominating petitions for Conservative Party committee positions under Election Law § 6-154(2).
Holding
No, because Election Law § 6-154(2) explicitly limits standing to challenge designating petitions for party positions to voters enrolled to vote for such party positions in the same election district.
Court’s Reasoning
The Court focused on the plain language of Election Law § 6-154(2), which states that written objections to a designating petition for a party position may be filed “by any voter enrolled to vote for such party position.”
The Court noted the legislative history, pointing out that prior to a 1978 amendment, the Election Law did not explicitly limit who could object to a nominating petition. The 1978 amendment added the language requiring objectors to be voters enrolled to vote for the specific party position.
The Court reasoned that the legislature intentionally added this limitation to resolve any ambiguity regarding the standing requirements for objecting to petitions for party positions.
The court acknowledged potential arguments about the undue burden of the requirement but stated that any redress should come from the legislature, not the courts. The court stated: “If there is indeed undue burden in such a requirement, as suggested, redress obviously lies with the Legislature and not the courts obliged to apply the statute as it has clearly been written.”
There were no dissenting or concurring opinions.