Matter of Hoffmann v. New York State Ind. Redistricting Commission
This case concerns an appeal from a CPLR article 78 proceeding seeking to compel the New York State Independent Redistricting Commission (IRC) to fulfill its constitutional duty to prepare and submit a second redistricting plan to the Legislature. Following the 2020 federal census, the IRC failed to achieve consensus and did not submit a second plan after its initial proposals were rejected. This led to legislative action and subsequent judicial intervention in Matter of Harkenrider v Hochul, where the Court of Appeals deemed the legislative maps unconstitutional and ordered court-drawn maps for the 2022 election. The Appellate Division, Third Department, found the petitioners' mandamus proceeding timely and concluded that the Harkenrider decision's remedy for the 2022 elections did not absolve the IRC of its ongoing, mandatory constitutional obligation. Consequently, the court reversed the lower court's dismissal, granting the petition and directing the IRC to immediately commence its duty to create and submit a second redistricting plan.