Wright v. Rockefeller | |
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Argued November 19, 1963 Decided February 17, 1964 | |
Full case name | Wright et al. v. Rockefeller, Governor of New York, et al. |
Citations | 376 U.S. 52 ( more ) 84 S. Ct. 603; 11 L. Ed. 2d 512; 1964 U.S. LEXIS 1774 |
Case history | |
Prior | Judgment for defendants, injunction denied 211 F. Supp. 460 (S.D.N.Y. 1962) |
Holding | |
A New York statute that delineated the boundaries of the congressional district in Manhattan Island did not segregate eligible voters by race and place of origin in violation of the Equal Protection and Due Process Clauses of the Fourteenth Amendment and in violation of the Fifteenth Amendment. Judgment of the U.S. District Court for the Southern District of New York affirmed. | |
Court membership | |
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Case opinions | |
Majority | Black, joined by Warren, Clark, Harlan, Brennan, Stewart, White |
Concurrence | Harlan |
Dissent | Douglas, joined by Goldberg |
Dissent | Goldberg, joined by Douglas |
Laws applied | |
U.S. Const. Amend. XIV; U.S. Const. Amend. XV; N.Y. State Law § 111. |
Wright v. Rockefeller, 376 U.S. 52 (1964), was a case in which the Supreme Court of the United States held that in cases involving allegations of improper racial gerrymandering, where the evidence was "equally, or more, persuasive" that racial considerations had not motivated the state legislature, the court will give deference to the findings of the district court. [1]
Appellants, a group of citizens and registered voters in the Seventeenth, Eighteenth, Nineteenth, and Twentieth Congressional Districts in Manhattan brought suit against New York state officials, including then Governor Nelson Rockefeller, in the United States District Court for the Southern District of New York challenging the constitutionality of the portion of New York's 1961 congressional apportionment statute which defined the four districts. [2] The District Court permitted Congressman Adam Clayton Powell, who represented the Eighteenth District, along with several other New York County officials, to intervene as defendants supporting the constitutionality of the statute. [2] The appellants claimed that apportionment statute deprived them of rights guaranteed by the Due Process and Equal protection portions of the Fourteenth Amendment and by the Fifteenth Amendment, which prohibit the government from denying or abridging the right to vote on account of race, color, or previous condition of servitude. [2] Specifically, they claimed that the statute "establish[ed] irrational, discriminatory and unequal Congressional Districts in the County of New York and segregat[ed] eligible voters by race and place of origin." [2]
The case was heard by a three judge panel of the District Court. Appellants presented maps, statistics, and other evidence demonstrating that African-Americans and Puerto Ricans comprised 86.3 per cent of the Eighteenth District, 28.5 per cent of the Nineteenth District, 27.5 per cent of the Twentieth District, but only 5.1 per cent of the Seventeenth District. [3] A majority of the District Court panel found that appellants had not made out their case. [4] One judge concluded that "no proof was offered by any party that the specific boundaries created by [the statute] were drawn on racial lines or that the Legislature was motivated by considerations of race, creed or country or origin in creating the districts." [4] One judge dissented, viewing the evidence as "tantamount for all practical purposes, to a mathematical demonstration" that the legislation was "solely concerned with segregating" white voters from non-whites. [5]
Four justices wrote opinions in this case. Justice Black wrote for the majority, and was joined by 6 other justices, including Justice Harlan, who also wrote a concurring opinion. Justices Douglas and Goldberg each wrote dissenting opinions, and each joined the others opinion.
The Court began with a recitation of the relevant factual and procedural background, and then turned to first question presented in the statement, whether "appellants sustained their burden of providing that the portion of [the statute] which delineates the boundaries of the Congressional districts in Manhattan Island segregates eligible voters by race and place of origin in violation [of the Constitution]." [6] The Court accepted the findings of the majority of the District Court that the appellants failed to prove that the New York Legislature was either motivated by racial considerations or in fact drew the districts on racial lines. [6] The Court accepted that there may have been evidence which could have supported an inference that the legislature was moved by racial considerations, but found that there was also evidence supporting the contrary inference that was "equally, or more, persuasive." [7] The Court accepted the finding that appellants failed to demonstrate that the statute was "the product of a state contrivance to segregate on the basis of race or place of origin," and therefore upheld the District Court's decision. [8]
Justice Harlan joined the opinion of the Court, but wrote separately, in a paragraph long concurrence, to comment that he believed that this case was governed by entirely different principles than in Wesberry v. Sanders , a case that had also been decided that day. [9]
Justice Douglas dissented, arguing that the case raised a similar question to the issue raised in Gomillion v. Lightfoot , where racial gerrymandering was used to deprive African Americans on the right to vote. [10] Douglas argued that though the right to vote was not being deprived, the redistricting was concentrating minority voters in particular districts and excluding them from others. [10]
Douglas recited the relevant facts, and concluded that "[t]he record strongly suggests that these twists and turns producing an 11-sided, step-shaped boundary between the Seventeenth and Eighteenth Districts were made to bring into the Eighteenth District and keep out of the Seventeenth as many Negroes and Puerto Ricans as possible." [11] Although he admitted that the District Court had not made such a finding, Justice Douglas concluded that, absent any rebuttal or challenge by the State, the only inference that could be drawn from the facts was that it was "not possible to say 'that race is irrelevant to districting.'" [12]
Douglas next addressed the argument advanced by the intervening parties that the districting plan was beneficial to minorities, because it allowed minority politicians an advantage in heavily minority districts. Douglas rejected this argument, referring to it as the theory of "separate but better off," and writing "[t]he fact that Negro political leaders find advantage in this nearly solid Negro and Puerto Rican district is irrelevant to our problem. Rotten boroughs were long a curse of democratic processes. Racial boroughs are also at war with democratic standards." [13]
Finally, Douglas compared the situation in the Manhattan districts to the Electoral Register System that the British instituted in India, and was also used in Lebanon. [14] Under that system, constituencies were separated by religion. [14] Douglas wrote that "Racial electoral registers, like religious ones, have no place in a society that honors the Lincoln tradition — 'of the people, by the people, for the people.'" [15] Such a system, Douglas argued, "is a divisive force in a community, emphasizing differences between candidates and voters that are irrelevant in the constitutional sense." [15]
Justice Goldberg wrote a separate dissent, arguing that the appellants had satisfied their burden of establishing that district boundaries had been purposefully drawn on racial lines. [16] Goldberg rejected the conclusion that the District Court had found to the contrary. The decision from the three-judge District Court contained a separate opinion for each, therefore, Goldberg argued that the District Court had made no findings of fact at all. [17] He then went on to discuss and criticize the constitutional standards applied by each of the District Court judges. In this light, he argued that the majority’s grounds for their decision, i.e., accepting the findings and constitutional standards of the District Court, was meaningless and an abdication of the Supreme Court’s responsibilities. [17] Goldberg further stated that the appellants had made sufficient showings of racially discriminatory intent in the redistricting plan to pursue their case.
Baker v. Carr, 369 U.S. 186 (1962), was a landmark United States Supreme Court case in which the Court held that redistricting qualifies as a justiciable question under the Fourteenth Amendment's equal protection clause, thus enabling federal courts to hear Fourteenth Amendment-based redistricting cases. The court summarized its Baker holding in a later decision as follows: "the Equal Protection Clause of the Fourteenth Amendment limits the authority of a State Legislature in designing the geographical districts from which representatives are chosen either for the State Legislature or for the Federal House of Representatives.". The court had previously held in Gomillion v. Lightfoot that districting claims over racial discrimination could be brought under the Fifteenth Amendment.
Kramer v. Union Free School District No. 15, 395 U.S. 621 (1969), was a United States Supreme Court decision in which the Court struck down a longstanding New York State statute requiring that to be eligible to vote in certain school district elections, an individual must either own or rent taxable real property within the school district, be the spouse of a property owner or lessor, or be the parent or guardian of a child attending a public school in the district. By a 5-to-3 vote, the court held that these voting requirements violated the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution.
Miller v. Johnson, 515 U.S. 900 (1995), was a United States Supreme Court case concerning "affirmative gerrymandering/racial gerrymandering", where racial minority-majority electoral districts are created during redistricting to increase minority Congressional representation.
Gomillion v. Lightfoot, 364 U.S. 339 (1960), was a landmark decision of the Supreme Court of the United States that found an electoral district with boundaries created to disenfranchise African Americans violated the Fifteenth Amendment.
Shaw v. Reno, 509 U.S. 630 (1993), was a landmark United States Supreme Court case in the area of redistricting and racial gerrymandering. After the 1990 census, North Carolina qualified to have a 12th district and drew it in a distinct snake-like manner in order to create a "majority-minority" Black district. From there, Ruth O. Shaw sued to challenge this proposed plan with the argument that this 12th district was unconstitutional and violated the Fourteenth Amendment under the clause of equal protection. In contrast, Reno, the Attorney General, argued that the district would allow for minority groups to have a voice in elections. In the decision, the court ruled in a 5–4 majority that redistricting based on race must be held to a standard of strict scrutiny under the equal protection clause and on the basis that it violated the Fourteenth Amendment because it was drawn solely based on race.
Braunfeld v. Brown, 366 U.S. 599 (1961), was a landmark case on the issue of religious and economic liberty decided by the United States Supreme Court. In a 6–3 decision, the Court held that a Pennsylvania blue law forbidding the sale of various retail products on Sunday was not an unconstitutional interference with religion as described in the First Amendment to the United States Constitution.
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Vieth v. Jubelirer, 541 U.S. 267 (2004), was a United States Supreme Court ruling that was significant in the area of partisan redistricting and political gerrymandering. The court, in a plurality opinion by Justice Antonin Scalia and joined by Chief Justice William Rehnquist and Justices Sandra Day O'Connor and Clarence Thomas, with Justice Anthony Kennedy concurring in the judgment, upheld the ruling of the District Court in favor of the appellees that the alleged political gerrymandering was not unconstitutional. Subsequent to the ruling, partisan bias in redistricting increased dramatically in the 2010 redistricting round.
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Colegrove v. Green, 328 U.S. 549 (1946), was a United States Supreme Court case. Writing for a 4–3 plurality, Justice Felix Frankfurter held that the federal judiciary had no power to interfere with malapportioned Congressional districts. The Court held that the Elections Clause in Article I, section IV of the U.S. Constitution left to the legislature of each state the authority to establish the time, place, and manner of holding elections for Congressional Representatives, and that only Congress could determine whether individual state legislatures had fulfilled their responsibility to secure fair representation for citizens.
Moore v. City of East Cleveland, 431 U.S. 494 (1977), was a United States Supreme Court case in which the Court ruled that an East Cleveland, Ohio zoning ordinance that prohibited Inez Moore, a black grandmother, from living with her grandchild was unconstitutional. Writing for a plurality of the Court, Associate Justice Lewis F. Powell Jr. ruled that the East Cleveland zoning ordinance violated substantive due process because it intruded too far upon the "sanctity of the family." Justice John Paul Stevens wrote an opinion concurring in the judgment in which he agreed that the ordinance was unconstitutional, but he based his conclusion upon the theory that the ordinance intruded too far upon the Moore's ability to use her property "as she sees fit." Scholars have recognized Moore as one of several Supreme Court decisions that established "a constitutional right to family integrity."
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Bush v. Vera, 517 U.S. 952 (1996), is a United States Supreme Court case concerning racial gerrymandering, where racial minority majority-electoral districts were created during Texas' 1990 redistricting to increase minority Congressional representation. The Supreme Court, in a plurality opinion, held that race was the predominant factor in the creation of the districts and that under a strict scrutiny standard the three districts were not narrowly tailored to further a compelling governmental interest.
Zemel v. Rusk, 381 U.S. 1 (1965), was a United States Supreme Court case regarding the right to travel and area restrictions on passports, holding that the Secretary of State is statutorily authorized to refuse to validate the passports of United States citizens for travel to Cuba and that the exercise of that authority is constitutionally permissible.
United States v. 12 200-ft. Reels of Film, 413 U.S. 123 (1973), was an in rem case decided by the United States Supreme Court that considered the question of whether the First Amendment required that citizens be allowed to import obscene material for their personal and private use at home, which was already held to be protected several years earlier. By a 5–4 margin, the Court held that it did not.
Harrison v. NAACP, 360 U.S. 167 (1959), is a 6-to-3 ruling by the Supreme Court of the United States which held that the United States District Court for the Eastern District of Virginia should have abstained from deciding the constitutionality of three barratry, champerty, and maintenance laws in the state of Virginia until state courts had had a reasonable chance to construe them.
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Schuette v. BAMN, 572 U.S. 291 (2014), was a landmark decision of the Supreme Court of the United States concerning affirmative action and race- and sex-based discrimination in public university admissions. In a 6-2 decision, the Court held that the Fourteenth Amendment's Equal Protection Clause does not prevent states from enacting bans on affirmative action in education.
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