New York’s 11th Congressional District Found to Violate State Constitution
By: Joseph T. Burns
On January 21, 2026, in a decision in the case of Williams v. Board of Elections of the State of New York, a Manhattan Supreme Court Justice held that the boundaries of New York’s 11th Congressional District were in violation of the state constitution. Specifically, the judge found that Congressional District 11 violated Article III, Section 4(c)(1) of the state constitution by diluting the votes of minority voters.
This proceeding was initially filed in October 2025, by plaintiffs who are voters in Manhattan and Staten Island. The current district, the plaintiffs argued, was in violation of both the state constitution and the state Voting Rights Act because minority voters in the district have less of an opportunity than white voters to elect a representative of their choice.
The district at issue is currently composed of all of Staten Island and part of Brooklyn. To remedy the alleged issues with the current district, the plaintiffs argued in favor of a new district that includes all of Staten Island and part of Manhattan.
The 11th Congressional District’s sitting Member of Congress, Nicole Malliotakis, along with voters in the district were permitted to intervene in the case. These intervenors along with the two Republican Commissioners of the New York State Board of Elections unsuccessfully moved to have the proceeding dismissed.
The court rejected the plaintiffs’ arguments that the 11th Congressional District is in violation of the state Voting Rights Act. It was held by the court that the state VRA, in matters of vote dilution, does not apply to Congressional Districts in New York State. Additionally, the court found that the state’s requirements for Congressional redistricting come from the state constitution and, therefore, could not be modified, altered, or impacted by the state VRA, which is a statute.
The court, however, did find that the 11th Congressional District is in violation of the state constitution. In its decision, the court found that the state constitution contains greater protections against racial vote dilution than the U.S. Constitution or federal law. But in its decision, the court partially relied on federal court decisions, specifically the U.S. Supreme Court decision in Thornburg v. Gingles.
The court found that there is a history of discrimination against minority voters in the 11th Congressional District. It also found that racial bloc voting occurs in the 11th District, making it difficult for minority-preferred candidates to be elected. Finally, the court found that there is a history of racial appeals in elections in the 11th Congressional District. Because of these factors and the “totality of the circumstances,” the court determined that the 11th Congressional District is in violation of the state constitution.
To remedy what it found to be unconstitutional vote dilution, the court ordered the state’s Independent Redistricting Commission to draw a new district by February 6, 2026, just two weeks from the decision. While the plaintiffs had requested that the court order a new district map that includes Staten Island and part of Manhattan, the court found that it was required by Article II, Section 5 of the state constitution as well as the Court of Appeals decisions in Harkenrider v. Hochul and Hoffmann v. NYS IRC to allow the IRC to draw a new district map.
Finally, this all occurs approximately one month before the first day for candidates – including candidates for Congressional District 11 – to begin circulating their designating petitions.
This decision has already had a major impact on New York State politics as well as the 2026 elections. The Intervenors have vowed to appeal the decision. We will continue to track developments in this case as well as its future effects on the 2026 Congressional elections in New York State, and we will provide updates when appropriate.
