Jersey City United Against the New Ward Map v. Jersey City Ward Commission

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 12, 2024
DocketA-0356-22/A-0560-22
StatusPublished

This text of Jersey City United Against the New Ward Map v. Jersey City Ward Commission (Jersey City United Against the New Ward Map v. Jersey City Ward Commission) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jersey City United Against the New Ward Map v. Jersey City Ward Commission, (N.J. Ct. App. 2024).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NOS. A-0356-22 A-0560-22

JERSEY CITY UNITED AGAINST THE NEW WARD MAP, DOWNTOWN COALITION OF APPROVED FOR PUBLICATION NEIGHBORHOOD ASSOCIATIONS, March 12, 2024 GREENVILLE NEIGHBORHOOD APPELLATE DIVISION ALLIANCE, FRIENDS OF BERRY LANE PARK, RIVERVIEW NEIGHBORHOOD ASSOCIATION, PERSHING FIELD NEIGHBORHOOD ASSOCIATION, SGT. ANTHONY NEIGHBORHOOD ASSOC., GARDNER AVENUE BLOCK ASSOCIATION, LINCOLN PARK NEIGHBORHOOD WATCH, MORRIS CANAL REDEVELOPMENT CDC, HARMON STREET BLOCK ASSOCIATION, CRESCENT AVENUE BLOCK ASSOCIATION, DEMOCRATIC POLITICAL ALLIANCE, and FRANK E. GILMORE, in his individual and official capacity as Ward F Councilman,

Plaintiffs-Appellants,

v.

JERSEY CITY WARD COMMISSION and JOHN MINELLA, in his official capacity as Chair of the Commission, Defendants-Respondents. ________________________________

JAMES CALDERON,

Plaintiff-Appellant,

CITY OF JERSEY CITY WARD COMMISSION, JOHN MINELLA, Chairman, SEAN J. GALLAGHER, Secretary, and Commissioners DANIEL E. BECKELMAN, PAUL CASTELLI, JANET LARWA, and DANIEL MIQUELI,

Defendants-Respondents. _______________________________

Argued November 27, 2023 – Decided March 12, 2024

Before Judges Gilson, DeAlmeida, and Bishop- Thompson.

On appeal from the Superior Court of New Jersey, Law Division, Hudson County, Docket Nos. L-0960-22 and L-0821-22.

Renée W. Steinhagen argued the cause for appellants in A-0356-22 (New Jersey Appleseed Public Interest Law Center, Inc., Matsikoudis & Fanciullo, LLC, and Yael Bromberg (Bromberg Law LLC), attorneys; Renée W. Steinhagen, Yael Bromberg, and William C. Matsikoudis, on the briefs).

A-0356-22 2 James Calderon, appellant in A-0560-22, argued the cause pro se.

Jason F. Orlando argued the cause for respondents (Murphy Orlando LLC, attorneys; Jason F. Orlando and Tyler Newman, on the briefs).

The opinion of the court was delivered by

GILSON, P.J.A.D.

Following the 2020 decennial United States Census, the City of Jersey

City Ward Commission (the Commission) redrew the six election wards for the

City of Jersey City (the City). In these two appeals, which we consolidate for

purposes of this opinion, plaintiffs challenge the ward boundaries and map

adopted by the Commission.

Plaintiffs appeal from orders dismissing their complaints in lieu of

prerogative writs, contending that the new ward map violates the Municipal

Ward Law (the MW Law), N.J.S.A. 40:44-9 to -18, the New Jersey Civil Rights

Act (the CR Act), N.J.S.A. 10:6-1 to -2, and their rights of free speech, free

association, and equal protection under the New Jersey Constitution. They also

argue that the Commission did not comply with the Open Public Meetings Act

(the OPMA), N.J.S.A. 10:4-6 to -21.

Having reviewed these arguments in light of the record and law, we affirm

in part and reverse in part. We affirm the dismissal of plaintiffs' claims asserting

A-0356-22 3 violations of their constitutional rights, the CR Act, and the OPMA. We reverse

the dismissal of the claims of violations of the MW Law. Resolution of those

statutory claims requires some, albeit limited, fact-finding. Thus, we remand

the MW Law claims for further proceedings.

I.

The Legislature allows municipalities to adopt a charter or form of

government under which a municipality is divided into wards for the purpose of

electing members of the municipal governing body. N.J.S.A. 40:44-10. When

a municipality adopts that form of government, the MW Law identifies the

commissioners who will create the wards and periodically reassess and adjust

those wards. See N.J.S.A. 40:44-11, -13. The MW Law provides that the

commission shall be composed of the members of the county board of elections

and the municipal clerk. N.J.S.A. 40:44-11.

The MW Law also provides that the municipal ward commission "shall"

divide the municipality into "compact and contiguous" wards that are roughly

equal in population. N.J.S.A. 40:44-14. In that regard, the MW Law states:

The ward commissioners shall fix and determine the ward boundaries so that each ward is formed of compact and contiguous territory. The population of the most populous ward so created shall not differ from the population of the least populous ward so created by more than [ten percent] of the mean population of the

A-0356-22 4 wards derived by dividing the total population of the municipality by the number of wards created. The most recent [f]ederal decennial census shall be used as the population determinant.

[Ibid.]

Wards must be evaluated and, if necessary, adjusted every ten years based

on the federal decennial census. In that regard, the MW Law states:

Within [three] months following the receipt by the Governor of each federal decennial census, the ward commissioners shall meet in the manner provided in subsection a. of this section and proceed to make such adjustments in ward boundaries as shall be necessary to conform them to the requirements of this act.

[N.J.S.A. 40:44-13(c).]

The City is, and has been for decades, divided into six election wards:

Wards A, B, C, D, E, and F. In 2020, the United States Census was conducted,

and, on September 16, 2021, the Governor promulgated the results. The 2020

Census revealed that Ward E, the largest ward by population in the City, was

fifty-nine percent more populous than Ward D, the least populous ward. As of

the 2020 Census, Ward E had 69,524 residents, while Ward D had 40,733

residents. Therefore, under the MW Law, the Commission had to redraw the

City's ward boundaries and related map.

A-0356-22 5 The MW Law required the Commission to hold at least one meeting,

which was to be within three months of the receipt of the 2020 Census by the

Governor. Ibid. The MW Law also provided that the Commission can hire and

be assisted by a surveyor, an engineer, and "other assistants as shall be necessary

to aid [the Commission] in the discharge of [its] duties." N.J.S.A. 40:44 -12.

The Commission was to prepare a report on the boundaries of the wards, together

with a map, and the report was to be certified by at least three Commissioners.

N.J.S.A. 40:44-15(a). Thereafter, the certified report and map were to be filed

with the county clerk, the Secretary of State, and the municipal clerk. Ibid.

Finally, the municipal clerk was to cause notice of the ward boundaries to be

published in a local newspaper within two weeks of the filing of the

Commission's report. N.J.S.A. 40:44-16.

After receiving the 2020 Census, the Commission held three public

meetings on December 15, 2021, January 14, 2022, and January 22, 2022. The

Commissioners also conducted several working sessions during that time, but

the Commissioners certified that no more than three Commissioners were

present at any one working session.

On January 22, 2022, after listening to approximately three hours of public

comment, the Commission voted to adopt new boundaries for the six wards and

A-0356-22 6 approved a new ward map (the 2022 Ward Map). The ward maps before and

after 2022 are depicted in the two maps set forth below:

As these maps reflect, the City is irregularly shaped because its boundaries

are based on rivers, harbors, bays, cliffs, and adjoining municipalities. T he

Commission made various adjustments to the boundaries of the six wards.

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