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Muntaqim/Hayden (Consolidated in 2nd Circuit)

Published: May 8, 2006

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







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