Brennan Center for Justice

Muntaqim/Hayden

Voting After Criminal Conviction

Case Summary

Muntaqim-Hayden was a challenge to NY State’s felony disenfranchisement provision, which bars people with felony convictions from voting while they are in prison or on parole. Because the criminal justice system targets African Americans and Latinos for arrest, prosecution, and conviction, these groups are disenfranchised at much higher rates than whites. The plaintiffs asserted that the law thus violates Section 2 of the Voting Rights Act (1965) because it constituted a denial of the vote on account of race. 

The case was a consolidation of two felony disenfranchisement cases arising in New York - Muntaqim v. Coombe and Hayden v. Pataki.

In Muntaqim, the federal District Court granted summary judgment to the State in January 2001, holding that the Voting Rights Act does not apply to felony disenfranchisement laws. A three-judge panel of the US Court of Appeals for the 2nd Circuit affirmed the District Court decision in April 2004, and the Supreme Court declined to review the case. In December 2004, however, the 2nd Circuit decided to rehear the case en banc (i.e., before the entire court).

In Hayden, the District Court dismissed the case in June 2004, and the plaintiffs appealed in July 2004.

On February 24, 2005, the 2nd Circuit Court of Appeals ordered that the Muntaqim and Hayden cases be consolidated.

The court, on its own motion, invited the Brennan Center to present an oral argument, and on June 22, 2005, oral arguments were presented to the en banc 2nd Circuit in the consolidated Muntaqim-Hayden case.

On May 4, 2006, the 2nd Circuit En Banc ordered the two cases de-consolidated.  The Court vacated the District Court’s opinion in Muntaqim v. Coombe, “on the ground that plaintiffs in that case lacked standing to bring a claim.”

The Court affirmed the District Court judgment in Hayden v. Pataki, based on its conclusion that “Congress did not intend or understand the Voting Rights Act to encompass” felon disenfranchisement statutes. 

For a briefing sheet on Hayden v. Pataki, click here. 

Rulings

Muntaqim v. Coombe
• District Court’s Order Granting Summary Judgment to State - January 2001
• 2nd Circuit Court of Appeals Panel decision - April 2004
• 2nd Circuit Court of Appeals En Banc decision - May 2006

   

  Hayden v. Pataki

• District Court’s Order Granting Defendants’ Motion for Judgment on Pleadings - June 2004
• 2nd Circuit Court of Appeals En Banc decision - May 2006

   

  Muntaqim/Hayden Consolidated

• 2nd Circuit Court of Appeals Order Granting Hearing En Banc for Hayden v. Pataki and consolidating it with Muntaqim v. Coombe- February 2005

Filings

Muntaqim v. Coombe
• Plaintiff-Appellant Brief in the 2nd Circuit
• Plaintiff-Appellant’s Brief in 2nd Circuit En Banc

   

  Hayden v. Pataki

• First Amended Complaint - January 2003
• En Banc Brief for Hayden Plaintiffs-Appellants - March 2005

Brennan Center Amicus Briefs

• Brennan Center Amicus Brief - August 9, 2002
• Brennan CenterAmicus Brief (En Banc) - January 28, 2005

Other Amici - En Banc

• American Civil Liberties Union and New York Civil Liberties Union - January 28, 2005
• Association of the Bar of the City of New York - January 28, 2005
• Center for Community Alternatives, National Association of Criminal Defense Lawyers, New York Association for Criminal Defense Lawyers, and the Sentencing Project - February 8, 2005
• Center for Constitutional Rights, The National Alliance for Formerly Incarcerated Persons, The Osborne Association, The Coalition for Parole Restoration, Voice of the Ex-Offender, the 11th Episcopal District Lay Organization, The Ordinary People Society, The Center for Law and Justice, and the Malcolm X Center - January 28, 2005
• Lawyers’ Committee for Civil Rights Under Law, People for the American Way Foundation, National Association for the Advancement of Colored People, and National Black Law Students Association Northeast Region - January 28, 2005
• NAACP Legal Defense & Educational Fund, Community Service Society of New York, and Center for Law and Social Justice at Medgar Evers College - February 4, 2005
• National Voting Rights Institute and Prison Policy Initiative - January 28, 2005

Press Center

• Leading Civil Rights Organizations Bring Expertise to a Pioneering Vote Restoration Case - January 15, 2003

For more information, please visit the website of the NAACP Legal Defense Fund, lead counsel in Hayden.