Matter of Hampton v. Meisser, 19 N.Y.2d 316 (1967)

A county political committee, unless restricted by party bylaws, has the authority under Election Law § 137(4) to designate a non-enrolled party member as a candidate for an office within a political subdivision of the county, even if that subdivision has its own committee, provided the county committee represents that subdivision.

Summary

This case concerns a challenge to the designation of Hampton, a Conservative, as a Republican candidate for Congress. The petitioner argued that the Nassau County Republican Committee lacked the authority to designate Hampton because Election Law § 137(4) requires the designation to be made by a committee *within* the political subdivision. The Court of Appeals reversed the lower courts, holding that the county committee *represents* the political subdivision and thus has the power to designate candidates, unless the party rules specify otherwise, or unless the authority has been delegated to a committee within the district.

Facts

Hampton, a member of the Conservative party, was designated by the Nassau County Republican Committee as a candidate for the Republican nomination for Member of Congress from the Fifth Congressional District, which is part of Nassau County. A legal challenge was brought to invalidate this designation, arguing it violated Election Law § 137(4), which governs the designation of non-enrolled party candidates.

Procedural History

The Special Term invalidated Hampton’s designation, interpreting Election Law § 137(4) to require that the designating committee be *within* the political subdivision. The Appellate Division affirmed, also relying on a prior case, *Matter of Dent v. Power*. The case then went to the New York Court of Appeals.

Issue(s)

Whether, under Election Law § 137(4), a county political committee has the authority to designate a non-enrolled party member as a candidate for an office within a political subdivision of the county, or whether that authority is exclusively reserved to a committee *within* that political subdivision.

Holding

No, because Election Law § 137(4) requires only that the designating committee *represents* the political subdivision, not that it be physically located *within* it. The Nassau County Republican Committee represents the Republican party within the Fifth Congressional District and had the authority to make the designation. The committee could have delegated this power, but because it didn’t, it retained that power.

Court’s Reasoning

The Court of Appeals found the lower courts’ interpretation of Election Law § 137(4) to be too restrictive. The court emphasized that the statute requires the designating committee to *represent* the political subdivision, not to be physically *within* it. The court reasoned that because the Nassau County Republican Committee undeniably represents the Republican party within the Fifth Congressional District, it possessed the requisite authority to designate candidates. The court also noted that the county committee had the option to delegate this power to a smaller committee within the Fifth Congressional District, but its decision not to do so meant it retained the power of designation. The court distinguished *Matter of Dent v. Power*, stating that *Dent* did not explicitly prohibit a county committee from designating a candidate for a political subdivision within its jurisdiction. The court cited *Matter of Licitra v. Power* and the Rules of the Nassau County Republican Committee to further support the county committee’s authority. The court essentially provided a flexible interpretation, allowing for county-level control unless explicitly restricted by party bylaws or delegated to a lower committee.