Lomenzo v. WMCA, Inc.
Headline: Court vacates part of a federal trial judge’s ruling as moot, halting federal review of whether several 1964 New York laws violated equal protection and related state-constitutional questions.
Holding: The Court vacated the District Court’s judgment as moot and did not decide whether the 1964 New York laws violated the Fourteenth Amendment’s Equal Protection Clause or implicated state-constitutional provisions.
- Ends this federal court ruling on constitutionality of the 1964 New York laws.
- Leaves equal protection questions unresolved by the Supreme Court.
- Removes the District Court’s related state-constitution rulings from effect.
Summary
Background
This dispute involved WMCA, Inc. (a broadcaster) and Lomenzo and others, who appealed different parts of a federal trial court’s judgment. The Court notes that it previously affirmed portions of the same judgment in WMCA, Inc. v. Lomenzo, 382 U.S. 4. The appeals now before the Court challenge whether several New York laws enacted in 1964 (chapters 977–978, 979, and 981) violate the Equal Protection Clause of the Fourteenth Amendment and whether the District Court properly relied on provisions of the New York Constitution.
Reasoning
All parties agreed that the contested parts of the District Court’s judgment were rendered moot by actions taken by the New York Court of Appeals in two decisions called In the Matter of Orans. Because of those state-court developments, the Supreme Court determined that the District Court’s judgment could not stand on the issues now appealed. The Court therefore vacated the District Court’s judgment insofar as it addressed whether the 1964 New York laws violated equal protection and whether the District Court could rely on the cited provisions of the state constitution. The Supreme Court did not reach the merits of the constitutional claims.
Real world impact
Vacating the judgment as moot removes the District Court’s ruling on these questions and ends this round of federal review. The Equal Protection claims and the state-constitution reliance remain undecided by this Court. The opinion notes that Justice Fortas took no part in this decision.
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