New Jersey congressional districts before (left) and after (right) theKarcher v. Daggett decision and court-ordered redistricting
Following the1980 United States census, the New Jersey Legislature had conducted decennial redistricting. The resulting map, which was considered heavily favorable to the Democratic Party and approved by Democratic governorBrendan Byrne, was used for the1982 elections. However, Republicans challenged the map under the "equal representation" clause ofArticle One, Section 2 of theUnited States Constitution. InKarcher v. Daggett, 462 U.S. 725 (1983), theSupreme Court of the United States (in an opinion written by former New Jersey judgeWilliam J. Brennan Jr.) ruled that the 1982 map violated the equal representation clause because its districts were not drawn to achieve as close to population equality as practicable. The Court ruled that all deviations, no matter how minimal, must be justified by a legitimate government interest. New Jersey was given a deadline of February 3, 1984 to draw a new U.S. Supreme Court-approved map for the 1984 House elections.[2]
Efforts to redraw the map pitted GovernorThomas Kean, a Republican, against the Democratic legislative majority. The initial replacement map, which passed the Assembly on January 6 and had a population variance of 0.06 percent, was advocated byNewark assemblymanWillie B. Brown as protecting the black-majority tenth district, while Republican counterproposals reduced the population variance further at the expense of the state's lone majority-minority district. Brown cited the Court's position that preserving minority voting strength "was a legitimate justification for including population deviations in redistricting plans."[2]
However, Kean vetoed the legislature's map, arguing that it was designed to preserve Democratic chances in the upcoming election, and no compromise was reached ahead of the February 3 deadline. As a result, a three-judge federal court panel (John Joseph Gibbons,Clarkson Sherman Fisher andStanley Brotman) considered five proposals, including the vetoed legislative map. The panel selected a map proposed by four of the five incumbent Republican U.S. representatives, citing its low population differences and compact districts.[3] Only twenty-five people separated the most and least populous districts, and the majority-black tenth district was preserved.[3] Kean said the result was not "an ideal solution" and called for abipartisan or nonpartisan commission for future redistricting,[3] which was eventually established by constitutional amendment in November 1995.
The most significant political change on the map in 1984 was in theeleventh district, represented by Democratic incumbentJoseph Minish since 1963. The new map removed several strongly Democratic urban areas in Bergen, Hudson, and Passaic counties and added suburban and rural areas in Morris, Sussex, and Warren, favoring Republicans. As a result, Minish was expected to draw a significant challenge in the 1984 elections.[3]
RepublicanDean Gallo defeated Democratic incumbent Joseph Minish. This district, which had been significantly revised as the result ofKarcher v. Daggett, consisted of parts ofEssex,Morris,Sussex andWarren counties.
The Republican Party would continue to hold this seat until2018.
This seat had been vacant since incumbent RepublicanEdwin Forsythe died on March 29, 1984. RepublicanJim Saxton won the open seat, as well as the special election to complete Forsythe's term.
District results
County results
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