Lavalle v. Board of Supervisors, Putnam County, 26 N.Y.2d 807 (1970)

Courts may impose temporary, interim weighted voting plans on malapportioned local governments until a permanent, constitutionally compliant apportionment plan is adopted, particularly in anticipation of new census data.

Summary

This case concerns the malapportionment of the Putnam County Board of Supervisors. The lower court directed the board to adopt a constitutionally sound apportionment plan by July 1, 1969, and implemented an interim weighted voting system until a permanent plan was in place. The Court of Appeals affirmed the imposition of the weighted voting plan as a temporary measure. However, recognizing the imminent availability of the 1970 federal census data, the Court modified the order to require the board to adopt a permanent apportionment plan within six months of receiving the census results. This decision highlights the judiciary’s role in ensuring fair representation and the use of interim measures to address malapportionment pending the creation of a permanent solution based on current population data.

Facts

The Putnam County Board of Supervisors was malapportioned, with each of the county’s six towns having one supervisor regardless of population size.

Procedural History

The Special Term court found the Board of Supervisors to be malapportioned and ordered them to create a constitutional apportionment plan by July 1, 1969. The court also implemented an interim weighted voting plan. The Appellate Division affirmed this order. The case was then appealed to the New York Court of Appeals.

Issue(s)

Whether the court-ordered interim weighted voting plan for a malapportioned county board of supervisors should be upheld, and whether the deadline for the board to adopt a permanent apportionment plan should be modified in light of upcoming census data.

Holding

Yes, the interim weighted voting plan is approved as a temporary measure. The order is modified to require the board to adopt a permanent plan within six months of the availability of the 1970 census data because this data would provide a more accurate basis for a permanent apportionment plan.

Court’s Reasoning

The Court approved the weighted voting plan solely as a temporary, interim measure, explicitly refraining from ruling on its constitutionality as a permanent solution. Recognizing that the 1970 federal census was forthcoming, the Court reasoned that the board should utilize the updated population data to create a more accurate and constitutionally sound permanent apportionment plan. The Court cited Franklin v. Mandeville, 26 Y 2d 65, 70, indicating its reliance on established precedent for adjusting apportionment plans based on updated census information. The decision emphasizes the importance of accurate population data in ensuring fair representation and the appropriateness of temporary measures to address malapportionment while awaiting such data. The court implicitly acknowledged that relying on outdated population figures could perpetuate inequities, thus necessitating a delay until the new census data became available. This ruling serves as a guide for courts addressing similar malapportionment issues in local governments, especially when new census data is anticipated. By modifying the lower court’s order, the Court of Appeals ensured that the permanent apportionment plan would be based on the most current and accurate population figures available.