Introduction

In the landmark case McNeil et al. v. Legislative Apportionment Commission of the State of New Jersey, the Supreme Court of New Jersey addressed the conflict between state constitutional mandates and federal voting rights laws. The plaintiffs, Anne M. McNeil and others, challenged the Legislative Apportionment Commission's (Commission) decision to divide New Jersey's two largest municipalities, Newark and Jersey City, into three legislative districts each, contrary to the New Jersey Constitution's stipulation of no more than two districts per municipality. The key issue revolved around whether adhering to the state’s political boundary requirements would infringe upon protections afforded by the federal Voting Rights Act (VRA) and the Supremacy Clause of the U.S. Constitution.

Summary of the Judgment

The Supreme Court of New Jersey held that enforcing the state's constitutional requirement to limit Newark and Jersey City to two legislative districts each would violate the Supremacy Clause, which grants federal law precedence over conflicting state provisions. The Commission's plan to establish three districts per municipality was deemed valid as it complied with the VRA, which aims to protect minority voters' rights by preventing the dilution of their electoral strength. The Court reversed the Appellate Division's ruling, which had favored the plaintiffs, and reinstated the Commission's redistricting plan.

Analysis

Precedents Cited

The Court extensively referenced several pivotal cases:

• BAKER v. CARR (1962): Established federal courts' jurisdiction over state apportionment issues under the Equal Protection Clause.
• REYNOLDS v. SIMS (1964): Affirmed the "one person, one vote" principle, requiring legislative districts to have roughly equal populations.
• SCRIMMINGER v. SHERWIN (1972): Held that strict adherence to county lines in redistricting could violate the Equal Protection Clause.
• Davenport v. Apportionment Commission (1974): Reinforced that population equality among districts supersedes political subdivision boundaries.
• Georgia v. Ashcroft (2003): Discussed the importance of minority representation and the use of "influence districts" under the VRA.
• THORNBURG v. GINGLES (1986): Established criteria for evaluating claims under Section 2 of the VRA, focusing on vote dilution and minority influence.

Legal Reasoning

The Court's decision was grounded in the Supremacy Clause of the U.S. Constitution, which mandates that federal law takes precedence over conflicting state laws. The Court reasoned that the VRA's objectives to protect minority voting rights necessitated deviations from New Jersey's constitutional boundaries for its largest municipalities. By allowing three districts each in Newark and Jersey City, the Commission effectively employed the "unpacking" strategy, distributing minority voters across multiple districts to prevent their dilution, thereby complying with both the VRA and the "one person, one vote" doctrine.

Additionally, the Court invoked the doctrine of contemporaneous and practical construction, emphasizing that long-standing practices and judicial interpretations should guide the application of constitutional provisions. Given that Newark and Jersey City had historically been divided into three districts without challenge, the Court found that this practice had effectively superseded the two-district limitation in practice to uphold federal imperatives.

Impact

This judgment reinforces the precedence of federal voting rights laws over state constitutional mandates in redistricting matters. It underscores the necessity for states to align their legislative apportionment plans with federal standards to protect minority voters from electoral dilution. Future redistricting efforts in New Jersey and potentially other states may similarly prioritize compliance with the VRA and the Supremacy Clause over state-specific boundary requirements, especially in areas with significant minority populations.

Complex Concepts Simplified

Supremacy Clause

A provision in the U.S. Constitution (Article VI, Clause 2) establishing that federal law takes precedence over state laws, and even state constitutions, when there is a conflict between the two.

Voting Rights Act (VRA)

A federal law enacted in 1965 aimed at eliminating racial discrimination in voting. It ensures that all citizens have equal opportunities to participate in the electoral process and to elect representatives of their choice.

Redistricting

The process of drawing electoral district boundaries, typically after a census, to ensure each district has roughly equal populations, adhering to legal and constitutional requirements.

One Person, One Vote

A legal principle established by the Supreme Court that ensures each person's vote has equal weight in elections, necessitating districts of roughly equal population.

Packing and Unpacking

Packing: Concentrating as many voters of one type into a single district to reduce their influence in other districts.
Unpacking: Distributing voters of a particular group across multiple districts to avoid diluting their electoral influence.

Influence Districts

Electoral districts created to maximize the political influence of minority groups without necessarily having a majority of minority voters in each district.