Hayden v. Paterson
Appealed from the Southern District of New York
Background: The appellants contest a judgment that dismissed the plaintiffs’ claims for relief under the Equal Protection Clause of the 14th Amendment of the U.S. Constitution and the 15th Amendment of the U.S. Constitution. The plaintiffs argue that the district court erred in dismissing their claim that, based on the discriminatory intent of prior constitutional convention delegates, New York’s current felon disenfranchisement laws violate the Equal Protection Clause of the 14th and 15th Amendments. More specifically, the plaintiffs contend racial animus motivated the adoption of New York’s several constitutional felon disenfranchisement provisions in the 1800s and that the animus remains legally operative today. They further argue New York Election Law §5-106(2) violates the Equal Protection Clause of the 14th Amendment because it disenfranchises, without justification, only those persons with felony convictions who are incarcerated or on parole, not persons receiving other sentences for felony convictions.
Ruling: Because the plaintiffs do not state a plausible claim of intentional discrimination and they do not state a plausible claim that New York Election Law §5-106(2) violates the Equal Protection Clause, the court affirms the district court’s grant of judgment on the pleadings to the defendants. The court remands to allow the plaintiffs to seek leave to amend their deficient complaint as to their intentional discrimination claim.
Juan Cartagena for the appellants, and Benjamin N. Gutman, assistant New York State Solicitor General, for the appellees