University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name Hayden v. Pataki VR-NY-0350
Docket / Court 1:00-cv-8586 ( S.D.N.Y. )
State/Territory New York
Case Type(s) Election/Voting Rights
Attorney Organization NAACP Legal Defense Fund
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 ... read more >
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.

David Priddy - 07/19/2011


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Issues and Causes of Action
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Issues
National Origin/Ethnicity
Hispanic
Plaintiff Type
Private Plaintiff
Race
Black
Voting
Vote dilution
Voter qualifications
Voter registration rules
Causes of Action Civil Rights Act of 1957/1960, 42 U.S.C. § 1971
42 U.S.C. § 1983
Defendant(s) State of New York
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.
Indexed Lawyer Organizations NAACP Legal Defense Fund
Class action status sought Yes
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer Yes
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year 2006
Case Ongoing No
Docket(s)
1:00-CV-08586 (S.D.N.Y.) 11/01/2010
VR-NY-0350-9000.pdf | Detail
PACER [Public Access to Court Electronic Records]
General Documents
First Amended Complaint 01/15/2003 (2003 WL 25655437)
VR-NY-0350-0001.pdf | WESTLAW | Detail
Document Source: Westlaw
Answer to Amended Complaint 04/14/2003 (2003 WL 25655438)
VR-NY-0350-0002.pdf | WESTLAW | Detail
Document Source: Westlaw
Memorandum and Order 06/14/2004 (2004 WL 1335921) (S.D.N.Y.)
VR-NY-0350-0008.pdf | WESTLAW | Detail
Document Source: Westlaw
Brief for Plaintiffs-Appellants 09/27/2004 (2004 WL 5658694)
VR-NY-0350-0003.pdf | WESTLAW | Detail
Document Source: Westlaw
Brief for Defendants-Appellees Pataki and Goord 11/24/2004 (2004 WL 5658693)
VR-NY-0350-0004.pdf | WESTLAW | Detail
Document Source: Westlaw
Reply Brief for Plaintiffs-Appellants 12/08/2004 (2004 WL 5658695)
VR-NY-0350-0005.pdf | WESTLAW | Detail
Document Source: Westlaw
Second Circuit Opinion 06/01/2006 (449 F.3d 305)
VR-NY-0350-0006.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Cabranes, Jose Alberto (Second Circuit, D. Conn., FISCR)
VR-NY-0350-0006
McKenna, Lawrence M. (S.D.N.Y.)
VR-NY-0350-0008 | VR-NY-0350-9000
Monitors/Masters None on record
Plaintiff's Lawyers Adegbile, Debo Patrick (New York)
VR-NY-0350-0001 | VR-NY-0350-0003 | VR-NY-0350-0005
Beverly, Alaina C. (New York)
VR-NY-0350-0003 | VR-NY-0350-0005
Cartagena, Juan (New York)
VR-NY-0350-0003 | VR-NY-0350-0005
Cartagena, Inan (New York)
VR-NY-0350-0001
Chachkin, Norman J. (New York)
VR-NY-0350-0001 | VR-NY-0350-0005
Gibbs, Joan (New York)
VR-NY-0350-0001 | VR-NY-0350-0003 | VR-NY-0350-0005
Haygood, Ryan Paul (New York)
VR-NY-0350-0005
Jones, Elaine R. (New York)
VR-NY-0350-0001
Kaufman, Risa (New York)
VR-NY-0350-0001 | VR-NY-0350-0003 | VR-NY-0350-0005
Nelson, Janai S. (New York)
VR-NY-0350-0001 | VR-NY-0350-0005 | VR-NY-0350-9000
Shaw, Theodore M. (New York)
VR-NY-0350-0001 | VR-NY-0350-0003 | VR-NY-0350-0005
Simmons, Esmeralda (New York)
VR-NY-0350-0001 | VR-NY-0350-0003 | VR-NY-0350-0005
Defendant's Lawyers Aronowitz, Michelle M. (District of Columbia)
VR-NY-0350-0004
Graber, Joel (New York)
VR-NY-0350-0002 | VR-NY-0350-9000
Klass, Gregory (New York)
VR-NY-0350-0004
Spitzer, Eliot (New York)
VR-NY-0350-0002 | VR-NY-0350-0004
Other Lawyers None on record

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