Case: Hayden v. Pataki

1:00-cv-08586 | U.S. District Court for the Southern District of New York

Filed Date: Nov. 9, 2000

Closed Date: 2006

Clearinghouse coding complete

Case Summary

On November 9, 2000, Plaintiffs filed this class action against the State of New York and its State Board of Elections in the United States District Court for the Southern District of New York. Plaintiffs, Black and Latino individuals who had been convicted of felonies under the laws of the state of New York and were incarcerated in the New York prison system or on parole, claimed that pursuant to New York Election Law § 5-106(2), they were not permitted to vote in state or federal elections, i…

On November 9, 2000, Plaintiffs filed this class action against the State of New York and its State Board of Elections in the United States District Court for the Southern District of New York. Plaintiffs, Black and Latino individuals who had been convicted of felonies under the laws of the state of New York and were incarcerated in the New York prison system or on parole, claimed that pursuant to New York Election Law § 5-106(2), they were not permitted to vote in state or federal elections, in violation of the New York Constitution.

Plaintiffs, represented by public interest and private attorneys, alleged that the state provisions denied suffrage to incarcerated and paroled felons on account of their race in violation of the United States Constitution, the Voting Rights Act of 1965 and customary international law. They cited the fact that Blacks and Latinos comprised nearly 87% of those currently denied the right to vote pursuant to § 5-106(2). Plaintiffs sought declaratory and injunctive relief enjoining defendants from implementing and enforcing § 5-106(2).

On July 10, 2003, the Defendants moved for a judgment on the pleadings pursuant to Federal Rules of Civil Procedure 12(c). In an order filed on June 14, 2004, the Southern District of New York (Judge Lawrence M. McKenna) granted the motion. The court found that the Plaintiffs' complaint did not sufficiently allege that § 5-106(2) was motivated by a discriminatory intent and dismissed all constitutional and statutory claims.

The Plaintiffs appealed this decision to the Second Circuit Court of Appeals. In an en banc decision, the Second Circuit held that the Voting Rights Act of 1965 did not encompass prisoner disenfranchisement provisions because (a) Congress did not intend the Voting Rights Act to cover such provisions; and (b) Congress made no clear statement of intent to modify the federal balance by applying the Voting Rights Act to these provisions. On May 4, 2006 the Court of Appeals dismissed the Plaintiffs' claims challenging New York Election Law § 5-106, affirmed the judgment of the district court, and remanded to the district court for further proceedings consistent with the opinion.

In a per curiam opinion, filed on June 1, 2006, the Second Circuit clarified the ruling of its May 4, 2006 opinion, explaining that the case was to be remanded to the District Court to address the issue of whether the plaintiffs-appellants properly stated a vote dilution claim based on New York's apportionment process, and, if so, to rule on the merits of that claim. On August 4, 2006, the District Court found that no further proceedings in the District Court were required, and that the case in the District Court need not be reopened.

Summary Authors

David Priddy (7/19/2011)

People


Judge(s)

Cabranes, José Alberto (Connecticut)

Calabresi, Guido (Connecticut)

Hall, Peter W. (Vermont)

Jacobs, Dennis G. (New York)

Katzmann, Robert A. (New York)

McKenna, Lawrence M. (New York)

Parker, Barrington Daniels Jr. (New York)

Pooler, Rosemary S. (New York)

Raggi, Reena (New York)

Sack, Robert David (New York)

Judge(s)

Cabranes, José Alberto (Connecticut)

Calabresi, Guido (Connecticut)

Hall, Peter W. (Vermont)

Jacobs, Dennis G. (New York)

Katzmann, Robert A. (New York)

McKenna, Lawrence M. (New York)

Parker, Barrington Daniels Jr. (New York)

Pooler, Rosemary S. (New York)

Raggi, Reena (New York)

Sack, Robert David (New York)

Sotomayor, Sonia (District of Columbia)

Walker, John Mercer Jr. (New York)

Wesley, Richard C. (New York)

Attorneys(s) for Plaintiff

Adegbile, Debo Patrick (New York)

Beverly, Alaina C. (New York)

Cartagena, Inan (New York)

Chachkin, Norman J. (New York)

Gibbs, Joan (New York)

Haygood, Ryan Paul (New Jersey)

Jones, Elaine R. (New York)

Kaufman, Risa (New York)

Nelson, Janai S. (New York)

Shaw, Theodore M. (New York)

Simmons, Esmeralda (New York)

Attorneys(s) for Defendant

Aronowitz, Michelle M. (District of Columbia)

Graber, Joel (New York)

Klass, Gregory (New York)

Spitzer, Eliot (New York)

Expert/Monitor/Master

Straub, Chester J. (New York)

Documents in the Clearinghouse

Document

Docket

Nov. 1, 2010 Docket
16

First Amended Complaint

2003 WL 25655437

Jan. 15, 2003 Complaint
17

Answer to Amended Complaint

2003 WL 25655438

April 14, 2003 Complaint
39

Memorandum and Order

2004 WL 1335921

June 14, 2004 Order/Opinion

Brief for Plaintiffs-Appellants

U. S. Court of Appeals for the Second Circuit

2004 WL 5658694

Sept. 27, 2004 Pleading / Motion / Brief

Brief for Defendants-Appellees Pataki and Goord

U. S. Court of Appeals for the Second Circuit

2004 WL 5658693

Nov. 24, 2004 Pleading / Motion / Brief

Reply Brief for Plaintiffs-Appellants

U. S. Court of Appeals for the Second Circuit

2004 WL 5658695

Dec. 8, 2004 Pleading / Motion / Brief

Second Circuit Opinion

U. S. Court of Appeals for the Second Circuit

449 F.3d 305, 2006 U.S.App.LEXIS 11187

June 1, 2006 Order/Opinion

Docket

Last updated May 13, 2022

Docket sheet not available via the Clearinghouse.

State / Territory: New York

Case Type(s):

Election/Voting Rights

Key Dates

Filing Date: Nov. 9, 2000

Closing Date: 2006

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Black and Latino individuals who had been convicted of felonies under the laws of the state of New York and were incarcerated in the New York prison system or on parole and who were denied the right to vote in state or federal elections.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

NAACP Legal Defense Fund

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Denied

Defendants

State of New York, State

Case Details

Causes of Action:

42 U.S.C. § 1983

Civil Rights Act of 1957/1960, 52 U.S.C. § 10101 (previously 42 U.S.C. § 1971)

Constitutional Clause(s):

Due Process

Equal Protection

Availably Documents:

Trial Court Docket

Complaint (any)

Non-settlement Outcome

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

Race:

Black

Voting:

Vote dilution

Voter qualifications

Voter registration rules

National Origin/Ethnicity:

Hispanic