Matter of Hosley v. LeBlanc, 96 N.Y.2d 413 (2001)
Article III, Section 7 of the New York State Constitution requires a candidate for the State Legislature to have resided in New York for five years immediately preceding the election.
Summary
This case concerns the residency requirements for candidates for the New York State Legislature, specifically regarding the interpretation of Article III, Section 7 of the New York Constitution. Petitioners challenged the candidacy of Kenneth LeBlanc, arguing that his continuous residency in California from 1987 to 1999 disqualified him due to not meeting the five-year state residency requirement immediately preceding the election. The Court of Appeals affirmed the Appellate Division’s ruling, holding that the five-year residency requirement must be satisfied in the five years immediately before the election to ensure familiarity with current state issues.
Facts
Kenneth P. LeBlanc was designated as the Independence and Democratic Party candidate for the New York State Assembly, 99th Assembly District.
Petitioners challenged LeBlanc’s candidacy, arguing he did not meet the New York State residency requirements because he lived in California from 1987 to 1999.
Article III, Section 7 of the New York Constitution requires state legislative candidates to have been a resident of New York for five years and of the relevant assembly or senate district for the twelve months immediately preceding the election.
Procedural History
The Supreme Court initially concluded that only the 12-month district residency needed to immediately precede the election, finding any five years of residency sufficient.
The Appellate Division reversed, holding that the five-year state residency must immediately precede the election.
The New York Court of Appeals granted review and affirmed the Appellate Division’s order.
Issue(s)
Whether Article III, Section 7 of the New York State Constitution requires a candidate for the State Legislature to reside in New York for the five years immediately preceding the election.
Holding
Yes, because the constitutional language, when interpreted in light of the record from the 1938 Constitutional Convention, indicates that the five-year residency requirement must be satisfied in the period immediately preceding the election.
Court’s Reasoning
The Court of Appeals based its decision on the intent behind the constitutional provision, as revealed in the records of the 1938 Constitutional Convention. The Court acknowledged that the constitutional language was open to multiple interpretations. However, reviewing the convention records clarified that the sponsors and opponents of the provision understood that the five-year residency period must immediately precede the election. The Court emphasized that the purpose of the residency requirement was to ensure that legislators possess a current and relevant understanding of the issues facing the state and the communities they represent.
The court cited the sponsor’s argument during the convention: “if a man lives in the State for 20 years and he moves out to San Francisco and stays there for five years, I still contend that being away for five years, he loses close touch with the local situation, and he should live here another five years, if he wants to be a legislator in the State.” This quote demonstrates the intent to ensure contemporaneous familiarity with local issues.
The Court reasoned that interpreting the provision to allow for non-consecutive residency would frustrate the objective of ensuring legislators are currently familiar with state issues. This decision highlights the importance of examining the historical context and legislative intent when interpreting constitutional provisions, especially when the text is ambiguous. It provides a clear rule for residency requirements for state legislative candidates in New York, emphasizing the need for recent and continuous connection to the state.