W. M. C. A., Inc. v. Simon

Background

A group of plaintiffs challenged New York State’s constitutional and statutory rules for drawing State Senate and Assembly districts. The three-judge federal court dismissed the complaint on January 11, 1962. The judges filed three separate opinions and did not agree on the same reasons for dismissal. The case raised claims that geographic apportionment diluted votes, especially in urban areas. The plaintiffs alleged that New York's constitutional and statutory apportionment provisions violated the federal Constitution. The Court also noted that motions to substitute parties were granted, and one Justice took no part in the decision.

Reasoning

The Court relied on its recent decision in Baker v. Carr, which said a federal court can hear a claim that votes were arbitrarily impaired by discriminatory geographic classification. Because Baker changed the law, the Court vacated the district court’s dismissal and sent the case back so the lower court can reconsider both justiciability and the merits in light of Baker. The Court followed its usual practice of vacating and remanding after a change in law and cited a prior remand case, Scholle v. Hare, saying the lower court should be the first to consider these issues. The decision does not resolve whether New York’s map is unconstitutional.

Real world impact

The ruling gives the federal court the chance to examine whether New York’s apportionment unfairly reduces the weight of some votes. If the lower court finds unconstitutional discrimination, legislative district lines could be challenged or redrawn. This decision is not a final judgment on the merits and the outcome could change after further proceedings.

Dissents or concurrances

Justice Harlan dissented, arguing he would have affirmed the dismissal or at least noted probable jurisdiction. He stressed that the lower court had rejected the federal claim on the merits and criticized the Court for remanding without clear guidance.