New Jersey congressional districts before (left) and after (right) the Karcher v. Daggett decision and court-ordered redistricting
Following the 1980 United States census, the New Jersey Legislature had conducted decennial redistricting. The resulting map, which was considered heavily favorable to the Democratic Party and approved by Democratic governor Brendan Byrne, was used for the 1982 elections. However, Republicans challenged the map under the "equal representation" clause of Article One, Section 2 of the United States Constitution. In Karcher v. Daggett, 462 U.S. 725 (1983), the Supreme Court of the United States (in an opinion written by former New Jersey judge William J. Brennan Jr.) ruled that the 1982 map violated the equal representation clause because its districts were not drawn to achieve as close to population equality as practicable. The Court ruled that all deviations, no matter how minimal, must be justified by a legitimate government interest. New Jersey was given a deadline of February 3, 1984 to draw a new U.S. Supreme Court-approved map for the 1984 House elections.[2]
Efforts to redraw the map pitted Governor Thomas Kean, a Republican, against the Democratic legislative majority. The initial replacement map, which passed the Assembly on January 6 and had a population variance of 0.06 percent, was advocated by Newark assemblyman Willie B. Brown as protecting the black-majority tenth district, while Republican counterproposals reduced the population variance further at the expense of the state's lone majority-minority district. Brown cited the Court's position that preserving minority voting strength "was a legitimate justification for including population deviations in redistricting plans."[2]
However, Kean vetoed the legislature's map, arguing that it was designed to preserve Democratic chances in the upcoming election, and no compromise was reached ahead of the February 3 deadline. As a result, a three-judge federal court panel (John Joseph Gibbons, Clarkson Sherman Fisher and Stanley Brotman) considered five proposals, including the vetoed legislative map. The panel selected a map proposed by four of the five incumbent Republican U.S. representatives, citing its low population differences and compact districts.[3] Only twenty-five people separated the most and least populous districts, and the majority-black tenth district was preserved.[3] Kean said the result was not "an ideal solution" and called for a bipartisan or nonpartisan commission for future redistricting,[3] which was eventually established by constitutional amendment in November 1995.
The most significant political change on the map in 1984 was in the eleventh district, represented by Democratic incumbent Joseph Minish since 1963. The new map removed several strongly Democratic urban areas in Bergen, Hudson, and Passaic counties and added suburban and rural areas in Morris, Sussex, and Warren, favoring Republicans. As a result, Minish was expected to draw a significant challenge in the 1984 elections.[3]
Republican Dean Gallo defeated Democratic incumbent Joseph Minish. This district, which had been significantly revised as the result of Karcher v. Daggett, consisted of parts of Essex, Morris, Sussex and Warren counties.
The Republican Party would continue to hold this seat until 2018.
This seat had been vacant since incumbent Republican Edwin Forsythe died on March 29, 1984. Republican Jim Saxton won the open seat, as well as the special election to complete Forsythe's term.
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