WMCA, Inc. v. Lomenzo
Headline: New York's legislative apportionment struck down for diluting urban votes, requiring reapportionment and restoring fairer voting power to city and suburban residents.
Holding:
- Requires New York to reapportion legislative districts to reflect population more closely.
- Restores stronger voting power to city and suburban residents previously underrepresented.
- District court must decide whether 1964 elections proceed under old maps.
Summary
Background
A group of individual citizens and voters from several heavily populated New York counties sued state and local officials, challenging provisions of the 1894 State Constitution and implementing statutes that set formulas for assigning seats in the State Senate and Assembly. They said the formulas overweighted rural areas and made votes in big cities count for less. The case reached a three-judge district court, which first dismissed the claim, then after reconsideration dismissed on the merits, and the plaintiffs appealed to this Court.
Reasoning
The central question was whether New York’s constitutional formulas for assigning legislative seats denied equal protection by underweighting urban votes. Relying on the Court’s equal-protection principle that both houses must be apportioned substantially by population, the Court found New York’s rules biased against more populous counties. The Court held the formulas produced substantial population disparities and diluted city and suburban voting strength, reversed the district court, and sent the case back for the lower court to decide remedies and timing.
Real world impact
The decision requires New York to adopt reapportionment plans that give legislative seats substantially according to population, reducing the advantage of sparsely populated counties. The Court left remedy details to the district court, which must decide whether the 1964 elections may proceed under the old plan or whether relief is needed sooner. The ruling directly affects who controls state legislatures and how citizens’ votes are weighted across the State.
Dissents or concurrances
The opinion notes there were dissenting Justices (Harlan and Stewart), indicating disagreement on aspects of the decision, but the main opinion controlled and reversed the lower court.
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?