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Moore v. Election Commissioners of Cambridge

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Moore v. Election Commissioners of Cambridge was decided by the Massachusetts Superior Court in 1941. The plaintiff alleged that the proportional representation system adopted by Cambridge, Massachusetts, voters in 1940 violated the Massachusetts and federal constitutions. On June 23, 1941, the state superior court ruled against the plaintiff, finding that Cambridge's proportional representation system did not violate the state or federal constitutions.

HIGHLIGHTS
  • The case: The plaintiff alleged that the proportional representation system adopted by Cambridge, Massachusetts, voters in 1940 violated the state and federal constitutions.
  • Outcome: The state superior court ruled against the plaintiff, upholding Cambridge's proportional representation system.
  • Background

    See also: Electoral systems in Massachusetts

    On November 5, 1940, voters in Cambridge, Massachusetts, approved a city charter amendment providing for the use of proportional representation in city council and school committee elections. The Cambridge system functions as follows:[1][2]

    1. Voters rank candidates by preference (first preference, second preference, etc.). No candidate can be given two preference rankings, and multiple candidates cannot share the same preference ranking.
    2. Candidates are ranked according to the number of first-preference voters they receive.
    3. The quota is determined by taking the number of valid ballots divided by the number of seats to be elected, plus one.
    4. Any candidate who meets the quote with first-preference votes is declared elected. Any votes that elected candidates receive in excess of the quota are redistributed to the next-preference candidate listed on the ballot. For example, if the quota is 2,500 and a candidate receives 3,000 first-preference votes, 500 of those votes will be transferred to the next-preference candidate listed on those ballots. Candidates receiving fewer than 50 first-preference votes are eliminated and their ballots are redistributed to the next-preference candidates as described above.
    5. After the first round of redistribution (described above), candidates meeting the quota are declared elected. The candidate with the fewest votes is eliminated and his or her first-preference votes are reallocated accordingly. The process repeats until all seats have been filled.

    Case history

    On November 29, 1940, the plaintiff, Andrew Moore, a registered Cambridge voter, petitioned the state supreme court for a writ of mandamus ordering the city's election commissioners to refrain from implementing the newly adopted proportional representation system, which Moore alleged violated the state and federal constitutions. The superior court agreed to hear the case.[1]

    Decision

    On June 23, 1941, the state superior court ruled against Moore, finding that Cambridge's proportional representation electoral system did not violate the state or federal constitutions. The court's opinion read, in part, as follows:[1]

    There is no constitutional objection to the Plan E form of government providing for proportional representation involving limited and preferential voting on the ground that its adoption by a city results in inequality among the several cities in the right of duly qualified voters to elect municipal officers. Plan E, as applied to Cambridge, is not unreasonable either in providing for limited voting and preferential voting or in its provisions respecting counting of ballots, although some element of chance may be involved, and is not in conflict with any specific provision of the Constitution of this Commonwealth or of the Federal Constitution.[3]

    See also

    External links

    Footnotes

    1. 1.0 1.1 1.2 Massachusetts Superior Court, "Andrew L. Moore vs. Election Commissioners of Cambridge," June 23, 1941
    2. City of Cambridge, "2017 Cambridge Voter Guide," accessed February 20, 2018
    3. Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.