This week- SCOTUS VRA Decision Reignites N.Y. Mid-Decade Redistricting Effort; Blakeman Goes to Court; Blakeman Raises Matching Funds; Working Families Candidate Remains on 113th A.D. Ballot; State Comptroller Primary Field Narrows. Rajkumar Remains on 28th A.D. Ballot; Looking Back at N.Y. Voting Rights; N.Y. Attorney General, Voting Rights Act Preclearance; Cervas Studies Mid-Decade Redistricting; Around the Nation from @RedistrictNet
LITIGATION
SCOTUS: Louisiana v. Callais Decision Reignites New York Redistricting Reform Efforts
For many years following the enactment of the federal Voting Rights Act of 1965, Section 2 of the law served as a sword, permitting the federal government and private parties to sue in court to strike down voting laws that had a discriminatory effort on minority voters. Section 5 of the law served as a shield by preventing discriminatory voting changes from taking effect before they could be implemented (through the “preclearance” process). Section 5 covered New York (Manhattan), Kings (Brooklyn) and The Bronx counties, essentially preventing any statewide voting law from going into effect without obtaining necessary federal approval. Today, as a result of last week’s Louisiana v. Callais decision, both sections of the law are inoperable.
The case was about whether Louisiana’s 2024 congressional map – which includes a second majority-Black district – violates the Constitution by using race in redistricting. In 2022, Louisiana approved a congressional map with only one majority-Black district, despite Black residents making up about a third of the state’s population. Black voters sued under Section 2 of the Voting Rights Act (VRA), claiming the map diluted their voting power. The decision resulted in a new map with two majority-Black districts. However, the map was challenged by a different group of voters who argued the new map was an unconstitutional racial gerrymander. The Court agreed that this new map was an unconstitutional racial gerrymander. As a result, Section 2 remains on the books but was made functionally inoperable through a series of new tests created by the Court that map challengers will not likely be able to overcome.
Reaction in New York to the Callais decision was swift and refocused attention on a pending constitutional amendment to permit the state to redraw congressional district lines as soon as 2028 (S.8467/A9014).
In a statement, N.Y. State Senate Deputy Minority Leader Michael Gianaris said that “(the) Supreme Court ruling is a five-alarm fire for the defense of free and fair elections. Already, Republican lead states are using the weakening of section 2 to manipulate congressional maps for partisan advantage at the explicit expense of black communities previously protected under the law. New York has the power to act in response and we must not hesitate to stand up in defensive of equal representation.”
We must advance our constitutional amendment, without delay, to allow for mid-decade redistricting that allows us to counteract this ongoing assault on equitable representation. If we do nothing, the entire nation will feel the consequences when other states rig congressional representation, our communities lose ground in Washington, our voices are diluted, and our ability to fight for the people we represent this weekend. We must fight back; there’s no time to waste.”
On the State Assembly side, Assemblyman Micah Lasher said that “the Supreme Court has continued its assault on voting rights in its recent decision in Callais, and Republican-controlled states are jumping at the chance to gerrymander their congressional districts. Florida has already acted. New York needs the legal authority to respond. That’s what my constitutional amendment does. It gives New York the ability to conduct its own mid-decade redistricting if another state moves first — so we’re not sitting on our hands while Republicans do away with free and fair elections. We need to act now.”
Governor Kathy Hochul said that “the Supreme Court has been chipping away at our elections for years. It is clearly carrying out Donald Trump’s will with this decision,” Hochul said. “New York has always led the fight for voting rights and we’ll lead again.” The Governor indicated she would work with state legislative leaders to amend New York’s laws to permit mid-decade redistricting.
Speaker Carl Heastie indicated that the legislature needs to address a redistricting reform amendment to the state constitution that would deal with structural deficiencies with the state commission process while Senate Majority Leader Andrea Stewart Cousins told a Democratic Party meeting that the legislature would act on a constitutional amendment before the June adjournment to permit mid-decade redistricting if any other state redraws its lines in mid-decade.
In a New York Post column on Friday, May 1, Joseph T. Burns, a Buffalo-based election lawyer who has assisted GOP candidates wrote that New York’s voters often vote independently and that just as voters rejected a 2021 redistricting reform amendment seen as friendly to Democrats, they might vote against future reforms that may appear to be blatantly partisan.
The state legislature can now be expected to act on an amendment after the state budget is adopted and before the early June session adjournment.
Nothing in the Callais decision directly addresses the long-established power of states to prevent racial discrimination in local governments through race-neutral means, thus state VRAs, including New York’s under N.Y. Elec. Law § 17-206(5), remain a critical path forward to protect voting rights for systemically marginalized voters. Further, State VRA vote dilution protections remain operable notwithstanding how Callais may be applied.
New York’s John R. Lewis Voting Rights Act provides protections against minority vote dilution at the county, city, and town levels while the state constitution provides protections for congressional and state legislative redistricting.
In the meantime, voting rights advocates are taking a wait-and-see approach to other anticipated attacks on minority voting rights. On Friday, U.S. Assistant Attorney General for Civil Rights Harmeet Dhillon said that the Justice Department will target minority districts across the nation where Section 2 was seen to have played a role in creating the district. She was quoted as saying that “those lines are going to change in coming years. So this is a sea change.”
Blakeman v. New York State Public Campaign Financing Board
On Tuesday, March 31 the New York Public Campaign Finance Board (PCFB) voted in a 4-3 decision along party lines to deny Republican gubernatorial candidate Bruce Blakeman, public campaign matching funds in his race because Blakeman’s running mate, Madison County sheriff Todd Hood, did not submit the required paperwork by the deadline.
On Wednesday, April 8, Blakeman filed a lawsuit in New York’s Albany County Supreme Court claiming it improperly disqualified him from receiving public matching funds. Oral arguments on the case were held on May 1, where Blakeman’s attorney, Adam Fusco, argued that the PCFB erred because it never created a form with space for both candidates to file and never told Blakeman anything was wrong with his filing.
Further, attorney Kevin Murphy, representing the Republican state Board of Elections Commissioners argued that the matching fund program’s rules allow candidates and committees to fix problems with applications, which is what the PCFB should allow for here.
However, attorney Christopher Massaroni (representing the PCFB) argued that Hood had a duty to register for the matching funds program under state law and because Hood did not register, the PCFB did not have a duty to notify Blakeman that his campaign was in violation. The PCFB also argued that there was no intent to deceive the Blakeman campaign on the part of the PCFB, and that the rules and statutes have been clear.
Judge Denise A. Hartman is expected to issue a ruling within two weeks.
ELECTIONS
Blakeman Raises Sufficient Contributions to Qualify for State Funds
Investigative reporting by Spectrum NY1 reports that the Republican Party’s nominee for Governor Bruce Blakeman would most likely meet the threshold to receive state public financing for his campaign. The report shows that Blakeman has raised at least $504,954 in matchable donations of $250 or less from at least 6,777 state voters. Candidates are required to raise $500,000 in matchable donations of $250 or less from at least 5,000 New York State donors.
After reviewing the donations provided to NY1, Blakeman appears to have met both thresholds. According to NY1’s review, he has received at least $504,954 in matchable donations from at least 6,777 New Yorkers.
State Board of Elections Declines to Remove Saratoga Area 113th AD Candidate from Ballot
The State Board of Elections has not taken action on a challenge to Thomas Kennedy, a candidate running on the Working families Party line in a 113th Assembly district race, claiming that the challenge goes beyond the Board’s jurisdiction. As reported last week, supporters of incumbent Democratic Assembly Member Carrie Woerner have also filed a challenge in Albany State Supreme Court to remove Kenny from the ballot. The lawsuit argues that Kenny was not enrolled in the Working Families Party when he filed his candidacy, making the petition signatures he witnessed invalid. Another part of the challenge alleges that Kenny did not meet the one-year district residency requirement. The case is pending before Justice Thomas Marcelle.
Halpin Challenger Removed From Ballot in 2nd Congressional District
The Suffolk County Board of Elections removed Jessica Murphy from the ballot to run in the Suffolk-based 2nd congressional district, leaving the Democratic Party field to former County Executive and state Assemblyman Patrick Halpin to run in November against GOP incumbent Congressman Andrew Garbarino. Murphy was short of the necessary 1250 signatures necessary to qualify for the ballot.
State Comptroller Race Narrows
Incumbent State Comptroller Tom DiNapoli may be facing only two opponents in the June primary after the State Board of Elections eliminated candidate Adem Bunkeddeko from the ballot. 15,000 valid signatures were required to qualify and Bunkeddeko filed 22,062 signatures but only 10,837 were found to be valid. Bunkeddeko had a court hearing in Albany County state supreme court in an attempt to get back on the Democratic Party primary ballot. A decision is pending. DiNapoli is also being challenged by Raj Goyle and Drew Warshaw.
Rajkumar Remains on 38th Assembly District Ballot
Assemblymember Jenifer Rajkumar will remain on the ballot in Queens 38th Assembly district after Supreme Court Justice Denise Johnson dismissed a challenge to her petitions by Democratic Socialist candidate David Orkin. Orkin attempted to remove Rajkumar from the ballot claiming that his campaign discovered at least seven forged signatures on Rajkumar’s petitions that were collected by the same people who collected 70% of Rajkumar’s signatures. Johnson did not rule on the merits of the case but found that Orkin’s attorneys had failed to serve the signature collectors with litigation-related documents.
A LOOK BACK AT NEW YORK VOTING RIGHTS
A Look Back at New York Voting Rights
Voting rights in New York have long been shaped by a complicated mixture of reform efforts, constitutional amendments, and litigation over electoral boundaries. While the state frequently portrays itself as a national leader in protecting voting rights, its history reveals persistent structural disputes over representation, redistricting, and electoral fairness.
One of the most important contemporary developments involves the state constitutional amendment process governing redistricting reform. In New York, constitutional amendments must pass through a three-step process: approval by the state legislature in two consecutive sessions, followed by ratification by voters in a statewide referendum. This procedure ensures that major electoral changes are subject to extended political scrutiny before becoming law.
The debate over redistricting remains ongoing. Many observers believe there is a high likelihood that another constitutional amendment addressing redistricting will appear on the ballot by next year, particularly as national political competition intensifies. Because other states have pursued mid-decade redistricting strategies to gain partisan advantage, lawmakers in New York have explored similar constitutional changes that would allow the state to redraw congressional maps outside the traditional ten-year census cycle.
Recent litigation demonstrates how volatile the issue remains. In 2026, the United States Supreme Court intervened in a dispute over a congressional district covering Staten Island and part of Brooklyn. The Court halted a lower court order that would have required redrawing the district before the upcoming election. The decision preserved the existing boundaries for the time being, highlighting how redistricting disputes can quickly escalate into federal constitutional conflicts with implications for control of Congress.
Concerns about voter suppression in New York are not limited to modern redistricting disputes. Historical debates over voting rights date back more than a century. A 1921 political commentary warned that structural barriers, including discriminatory election rules and unequal political representation, could suppress participation among marginalized communities. Although New York was not among the Southern states directly targeted by federal voting oversight, similar concerns about unequal access to the ballot periodically emerged throughout the twentieth century.
These issues resurfaced during debates surrounding Section 5 of the federal Voting Rights Act, which required jurisdictions with a history of discrimination to obtain federal approval before changing voting laws. In later Supreme Court litigation challenging the provision, Chief Justice John Roberts argued that the geographic formula used to determine which states were subject to preclearance had become outdated. Critics countered that dismantling the provision would weaken protections against discriminatory voting practices.
New York responded to the erosion of federal oversight by adopting its own voting rights protections. The John R. Lewis Voting Rights Act of New York was enacted to strengthen safeguards against vote dilution and discrimination at the state level. The law allows courts to review local election systems that weaken minority voting power and provides additional mechanisms for enforcing equal access to the ballot.
Taken together, these developments illustrate the evolving nature of voter suppression debates in New York. While the state often frames itself as a defender of voting rights, disputes over redistricting, judicial intervention, and constitutional reform demonstrate that the struggle over fair political representation remains far from settled.
VOTING RIGHTS ACT
N.Y. Attorney General’s Office Preclearance
1382 Putnam County Board of Elections- poll site location- new submission- under review
1203 Onondaga County Board of Elections- poll site location- granted
All submissions can be viewed at: https://nyvra-portal.ag.ny.gov/
MID-DECADE REDISTRICTING
Professor Cervas Looks at Mid-Decade Redistricting Impacts
In a new report, Carnegie Mellon’s Assistant Teaching Professor Jonathan Cervas looks at the impact of mid-decade redistricting across the nation. Cervas writes that “results indicate that Republican-controlled states generally realized limited gains from recent redistricting efforts. In many cases, these states had already implemented highly partisan maps, which constrained the potential for additional advantage. Where changes did occur, they often involved the removal or reconfiguration of minority-opportunity districts following changes in the legal environment surrounding Section 2 of the Voting Rights Act. In contrast, Democratic gains tend to be larger. This reflects both the larger populations of states such as California and Virginia and the fact that these states began from relatively neutral districting baselines, creating greater potential for change.
“Overall, the results suggest that Democrats are currently better positioned in this phase of mid-decade redistricting. Although fewer Democratic-leaning states have altered their maps, those that have done so are both more populous and were previously drawn under more neutral criteria. By contrast, many Republican-led redistricting efforts occurred in states that had already been optimized for partisan advantage, limiting the magnitude of additional gains.
“Under a range of scenarios, Republican redistricting efforts yield relatively small net changes, while Democratic efforts produce larger potential gains. This asymmetry raises a strategic question for Republican mapmakers. In particular, the responsive actions taken in large Democratic states — such as California and Virginia — appear to have offset, and in some cases exceeded, expected Republican gains. These responses may not have been fully anticipated, suggesting that some Republican strategies were formulated under assumptions that did not account for reciprocal institutional changes in opposing states.
“These conclusions should be interpreted with caution given the ongoing legal and institutional uncertainty surrounding redistricting. The Supreme Court’s decision in Louisiana v. Callais has created the possibility of further map revisions before the 2026 election. However, the electoral calendar imposes practical constraints, as many states have already entered critical stages of the election process. As a result, the ultimate configuration of district maps — and their electoral consequences — remains unsettled.”
The full report can be read here: http://bit.ly/3R1PMlQ
Professor Cervas served as the Special Master to the state supreme court in 2022. He created the maps used for the 2022 congressional map and the current state senate map.
AROUND THE NATION
From The Redistrict Network (@RedistrictNet)
April 27: Governor DeSantis releases proposed Florida congressional map to Fox News. More below. — @RedistrictNet [from X]
April 29: The US Supreme Court rules the Voting Rights Act did not compel Louisiana’s second majority-minority district, making SB8 an unconstitutional racial gerrymander.
While the court did not strike down Sect. 2, it appears have have drastically reduced its usefulness by changing the standards to prove violations of the Gingles prongs, making it far more difficult (must control for partisanship) — @RedistrictNet [from X]
April 29: The decision in Louisiana v. Callais has triggered a special session to begin in 21 days to redraw Mississippi’s state Supreme Court map. — @RedistrictNet [from X]
April 29: Governor Hochul says she will work with the state legislature to change New York’s redistricting process. — @RedistrictNet [from X]
April 29: Governor JB Pritzker says Illinois has options for pushing back against the Louisiana v. Callais (VRA decision). — @RedistrictNet [from X]
April 29: Florida’s proposed congressional map has passed the FL House and Senate. It now heads to Governor DeSantis for signature. — @RedistrictNet [from X]
April 30: Louisiana Gov. Jeff Landry has declared a state of emergency to suspend U.S. House primaries in order to allow additional time to redraw the state’s congressional map. — @RedistrictNet [from X]
May 1: Plaintiffs have appealed Wisconsin Business Leaders for Democracy v. WEC, a case arguing that Wisconsin’s congressional map is an unconstitutional, anti-competitive gerrymander, to the Wisconsin Supreme Court.
The motion asks the Wisconsin Supreme Court to consider the appeal before the current term concludes and to decide whether to send the case back to the judicial panel. — @RedistrictNet [from X]
May 1: Alabama Gov. Kay Ivey has called a special legislative session for May 4, 2026 in Montgomery. The session will allow legislators to consider special primary elections for congressional and state senate districts whose boundaries are impacted by court action.
The special session is predicated on the idea that Alabama will imminently receive favorable outcomes from the courts on its current redistricting litigation. — @RedistrictNet [from X]
May 1: Tennessee Gov. Bill Lee has called a special session to review the state’s congressional map. The legislative session will begin on Tuesday, May 5. — @RedistrictNet [from X]
May 2: President Trump urges Mississippi lawmakers to redraw the state’s congressional map. — @RedistrictNet [from X]
INSTITUTE RESOURCES
The New York Elections, Census and Redistricting Institute has archived many resources for the public to view on our Digital Commons Page.
Our Redistricting Resources page contains resources on the John R. Lewis Voting Rights Act. You can access the page here: https://digitalcommons.nyls.edu/redistricting_resources/
Archived Updates can be accessed here: https://digitalcommons.nyls.edu/redistricting_roundtable_updates/
Please share this weekly update with your colleagues. To be added to the mailing list, please contact [email protected]
The N.Y. Elections, Census & Redistricting Institute is supported by grants from the New York Community Trust, New York Census Equity Fund, the Mellon Foundation, and the New York City Council. This report was prepared by Jeff Wice, Esha Shah, Alexandria Sanatore & Jason Fierman of @RedistrictNet.