WMCA, Inc. v. Lomenzo

1965-10-11

Headline: New York reapportionment plan affirmed for temporary use, letting the state hold a 1965 special legislative election under Plan A while broader legal questions remain unresolved.

Holding: The Court granted the motion to affirm and upheld the lower court’s judgment, allowing New York’s Plan A to be used temporarily for the 1965 special legislative election while further review continues.

Real World Impact:

Permits New York to hold the 1965 special legislative election under Plan A despite state-court invalidation.
Temporarily suspends the State Constitution’s 150-member Assembly requirement for the 1966 Legislature.
Signals a full merits review is still expected and legal questions remain unresolved.

Topics: legislative apportionment, redistricting, state elections, federal-state relations

Summary

Background

A media company and other challengers sued New York state officials over the State’s new legislative map, called Plan A, which the Legislature adopted to comply with a federal three-judge court order requiring a valid apportionment for a November 1965 election lasting one year. The federal district court found Plan A acceptable for that special election, but the New York Court of Appeals later held Plans A through D invalid under the State Constitution’s 150-member Assembly rule. The Supreme Court’s brief per curiam order granted the motion to affirm and affirmed the lower court judgment.

Reasoning

The central question was whether the federal courts could allow Plan A to be used temporarily despite a state-court ruling that the plan violated New York’s Constitution. By affirming the district court, the Supreme Court effectively approved the plan’s temporary use to meet the federal court’s implementation schedule. A concurring Justice explained that the Court viewed Plan A as a temporary measure, that final plans must satisfy both state and federal constitutional requirements, and that further full consideration of the issues on the merits remains necessary.

Real world impact

The ruling lets New York proceed with the special 1965 legislative election under Plan A and suspends the State Constitution’s 150-member Assembly requirement for the one-year Legislature created by that election. The decision is not a final answer on all constitutional questions about apportionment or redistricting; a full merits decision is still expected.

Dissents or concurrances

Justice Harlan joined the affirmance but wrote separately to clarify the Court’s view, warned about federal-state tensions, and said a merits decision is unavoidable.