WRIGHT Et Al. v. ROCKEFELLER, GOVERNOR OF NEW YORK, Et Al.

1964-03-23
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Headline: Court affirms dismissal of challenge to Manhattan congressional map, finding appellants did not prove racial gerrymandering and allowing New York’s 1961 district lines to remain in effect.

Holding:

Real World Impact:
  • Leaves New York’s 1961 Manhattan congressional district lines in effect.
  • Affirms that plaintiffs must prove districts were drawn on racial lines.
  • Does not rule on population-equality claims about unequal district sizes.
Topics: racial gerrymandering, congressional districting, voting rights, Manhattan district map

Summary

Background

A group of Manhattan voters challenged part of New York’s 1961 law that set four congressional districts on Manhattan (the 17th–20th). They said the map “ghettoized” neighborhoods, concentrating Black and Puerto Rican voters in the 18th district while excluding them from the 17th, and relied on maps and census statistics to show large racial disparities among the four districts. New York officials and local leaders, including the 18th district’s Congressman, defended the map; the three-judge District Court heard the case and issued separate opinions.

Reasoning

The central question was whether the challengers proved the legislature drew the district lines because of race or national origin. The Supreme Court accepted the District Court majority’s finding that appellants had not carried that burden. The Court explained there were conflicting inferences from the record, noted demographic concentration of minority voters in one area made even splits difficult, and concluded the challengers failed to show a state contrivance to segregate voters. The Court therefore affirmed the lower court’s dismissal of the complaint.

Real world impact

The ruling leaves New York’s 1961 Manhattan congressional lines in effect and rejects this particular racial-motive challenge. The Court expressly did not decide whether the map might violate rules about equal population among districts, so other legal challenges on population equality were left open. The decision depends on the evidence burden the challengers presented in this record.

Dissents or concurrances

Justice Harlan joined the Court on the limited issue presented. Justices Douglas and Goldberg dissented, arguing the uncontradicted statistics and boundary shapes established a prima facie case of racial gerrymandering and that the State failed to rebut that inference, so they would have found the map unconstitutional.

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