Hayden v. Pataki: Taking Race out of the Voting Rights Act

May 8, 2006
Guest Post

by Justin Levitt, Associate Counsel, Brennan Center for Justice at NYU School of Law. The Brennan Center participated as amici curiae in support of the Plaintiffs-Appellants in this case.
Yesterday, from the U.S. Courthouse named for former Supreme Court Justice Thurgood Marshall, the Second Circuit effectively amended the Voting Rights Act, giving the green light to racial discrimination.
The text of the Voting Rights Act states that "[n]o voting qualification or prerequisite to voting or standard, practice, or procedure" may be used to deny or dilute the right to vote on account of race. It is a landmark law: after two centuries of racial discrimination in voting, Congress finally responded with the full power of the Fifteenth Amendment. No denial or dilution of the vote on account of race. Period.
This context makes the Second Circuit's en banc decision in Hayden v. Pataki doubly remarkable. It ignores the clear and categorical statutory text of the Voting Rights Act, to carve out one electoral restriction that, unlike any other, may be freely used in a way that discriminates on the basis of race. And it does so in an opinion that barely acknowledges that racial discrimination is at issue.
In Hayden, the en banc court addresses New York Election Law

Re: Hayden v. Pataki: Taking Race out of the Voting Rights Act

I, however, as a New Yorker and interested individual, heard the case for the first time when it was handed down. From that, I take the thought that more and more effective public outreach may be needed in the course of litigation like this in the future. No one, not even appellate judges, decide cases like this one in a social and political vacuum.

Post new comment

The content of this field is kept private and will not be shown publicly.
  • Web page addresses and e-mail addresses turn into links automatically.
  • Allowed HTML tags: <a> <em> <strong> <cite> <code> <ul> <ol> <li> <dl> <dt> <dd>
  • Lines and paragraphs break automatically.

More information about formatting options

By submitting this form, you accept the Mollom privacy policy.