Brooklyn Heights Ass’n v. Macchiarola, 82 N.Y.2d 100 (1993)

A City Districting Commission’s decision, based on a reasonable policy of adhering to census block boundaries, will be upheld when balancing competing districting criteria, even if it arguably impacts neighborhood integrity.

Summary

Following the abolition of the New York City Board of Estimate, a City Districting Commission was formed to redraw City Council districts. The Commission, tasked with creating a Latino-majority district, included a waterfront tabulation block in that district despite objections from Brooklyn Heights residents who claimed the area was historically part of their neighborhood. The Court of Appeals reversed the lower courts, holding that the Commission’s decision to avoid splitting tabulation blocks was a reasonable policy choice to effectuate the Charter’s requirement that census data be used and the decision was not arbitrary or capricious.

Facts

After the New York City Board of Estimate was declared unconstitutional, a City Districting Commission was appointed to redraw City Council districts. To create a Latino-majority district (District 38), the Commission created a “land bridge” using 11 tabulation blocks, including block 105, a long waterfront area. Brooklyn Heights residents (in District 33) objected, claiming the northern part of block 105 and adjacent piers were historically part of their neighborhood and should be included in their district.

Procedural History

Brooklyn Heights residents and civic groups filed an Article 78 proceeding challenging the districting plan. The Supreme Court granted the petition, ordering the district lines redrawn. The Appellate Division affirmed. The City appealed to the Court of Appeals as of right.

Issue(s)

Whether the City Districting Commission acted arbitrarily and capriciously in declining to split a census tabulation block to preserve a neighborhood’s integrity when balancing competing districting criteria mandated by the City Charter?

Holding

No, because the Commission’s decision to avoid splitting tabulation blocks was a reasonable policy choice, and the Charter only requires that districting criteria be applied “to the maximum extent practicable,” allowing for flexibility and compromise.

Court’s Reasoning

The Court emphasized that the Commission was mandated to use the “final count results” of the 1990 census and adopted a policy of not splitting tabulation blocks, the smallest geographical units for which census data was available, to implement this mandate. The Court deferred to the Commission’s reasonable policy choice related to implementing the technical requirements of districting. The Court noted the Charter only required criteria to be applied “to the maximum extent practicable,” indicating a need for flexibility. The Court stated: “It is not our role to second-guess the Commission’s reasonable policy choice related to implementing the technical requirements of districting.” The Court found that the Commission’s policy was directly and reasonably related to implementing the census requirement and was not arbitrary or capricious. Because the land-based portion of block 105 was dispositive, the court declined to address the issue of the piers, stating, “In view of our conclusion with regard to block 105, it is unnecessary to consider the disposition of the five disputed piers, because they would not be contiguous to District 33 in any event”.