In the Matter of Steven Glickman v. Zackary Laffin et al.

Summary

The New York Court of Appeals held that Steven Glickman's 2014 registration to vote in Washington, D.C. severed his continuous New York electoral residency for purposes of the State Constitution's five-year residency requirement for legislative candidates. The court reversed the Appellate Division and reinstated the order invalidating Glickman's designating petitions.

Holdings

1. A candidate may have more than one residence but may not have more than one electoral residence. By registering to vote in Washington, D.C. and attesting that he did not claim voting residence or the right to vote in any state or territory, Glickman broke the chain of New York electoral residency and could not establish the constitutionally required continuous five-year New York residency.
2. Glickman's designating petitions were properly invalidated because he could not satisfy the five-year constitutional New York residency requirement.

Questions Presented

1. Whether Glickman's registration to vote in Washington, D.C., precluded him as a matter of law from establishing the continuous five-year New York residency required for legislative candidates by the New York Constitution.
2. Whether the designating petitions for Glickman's State Senate candidacy should be invalidated for failure to satisfy the constitutional residency requirements.

Disposition

reversed