United Jewish Organizations v. Carey
The ruling on United Jewish Organizations v. Carey addressed the constitutionality of reapportionment plans for voting districts based solely upon racial factors. Because the state could provide evidence that the plan followed the actions required in the Voting Rights Act of 1965, and did not prevent white or nonwhite voters from exercising their right to participate in the political process by the redistricting of Kings County, the Court found that the reapportionment plan did not violate Fourteenth and Fifteenth Amendment rights of the Hasidic community of Williamsburgh.
Prior to 1974, it was determined that the Kings, New York (Manhattan), and Bronx Counties utilized a literacy test to qualify voters, and that in 1968, fewer than 50 percent of the voting age residents of these counties participated in the presidential election. These two instances caused the state to be subject to provisions under the Voting Rights Act of 1965 that prohibited the discrimination of voters based on racial considerations. In May of 1974, in order to comply with the act, New York State submitted a plan to the attorney general to reapportion the voting districts of Kings County. This plan was meant to realign voting districts to create nonwhite majorities. While this reapportionment did not change the size of the districts, it did change the number of nonwhites in the districts to an approximate 65 percent majority.
In particular, the Hasidic Jewish community of Williamsburgh was divided in half and one portion was reassigned to a neighboring electoral district. As a result of this redistricting, the Hasidic community claimed that their rights under the Fourteenth Amendment and Fifteenth Amendment of the U.S. Constitution had been violated. Their claim was that the reapportionment devalued their collective effectiveness by reducing it "solely for achieving a racial quota, and that they were assigned to electoral districts solely on the basis of race." The Hasidic community identified this as a case of racial gerrymandering, or the division of a county to create voting majorities in several districts while concentrating the voting minorities in as few districts as possible.
The district court dismissed the case, stating that the Hasidic Jewish community was not recognized as a separate community and "enjoyed no constitutional right in reapportionment" as such. The court of appeals affirmed the decision. A writ of certiorari was issued whereby the proceedings were remanded to the Supreme Court for review and action. The Supreme Court justices, after review and deliberation, also upheld the decision.