Hayden v. Pataki

Hayden v. Pataki, 449 F.3d 305 (2nd Cir. 2006), was a legal challenge to New York State's law disenfranchising individuals convicted of felonies while in prison and on parole. New York State is one of the 47 states to prohibit citizens from voting while in prison.

The initial pro se complaint was filed in the U.S. District Court for the Southern District of New York, by Joseph Hayden on September 12, 2003.

The plaintiff, Joseph Hayden, a former incarcerated felon and Campaign Director at nonprofit Unlock the Block, argues that because the law has a disproportionate impact on African Americans it violates Section 2 of the federal Voting Rights Act as a denial of the right to vote on account of race, in addition to violating the First, Fourteenth, and Fifteenth Amendments. The U.S. District Court dismissed the case as not violating Section 2 of the Voting Rights Act, nor of violating any of the Constitutional Amendments.

In an en banc rehearing of a panel decision, the Second Circuit held that the law did not violate the Voting Rights Act.

New York State later restored voting rights to people on parole, first by executive order in 2018, and then by law in 2021. However, people in prison are still unable to exercise the right to vote in New York.