2006), was a legal challenge to New York State’s law disenfranchising individuals convicted of felonies while in prison and on parole.

The plaintiff, Jalil Abdul Muntaqim who was serving a life sentence at the time, argued that the law had a disproportionate impact on African Americans and therefore violated Section 2 of the federal Voting Rights Act as a denial of the right to vote on account of race.

In 1974, Muntaqim was convicted on two counts of murder in the first degree for these killings, and received a prison term of twenty-five years to life.

Because he is serving a life term, Muntaqim would never again be allowed to vote under New York's existing felon-disenfranchisement law unless he were to be pardoned.

The United States Court of Appeals affirmed dismissal of the complaint on the grounds that section 2 of the Voting Rights Act does not apply to felon disenfranchisement statutes.

On November 8, 2004 the Supreme Court denied Muntaqim's petition for certiorari, thus declining to hear the case.

On July 18, 2000, the magistrate judge filed a report and recommendation that defendants' motion be granted and Muntaqim's complaint dismissed in its entirety.

On June 4, 2002, the Circuit Court, of its own volition (sua sponte) appointed appellate counsel to assist Muntaqim.

[7] On November 8, 2004, the Supreme Court declined to hear Muntaqim's case (writ of certiorari denied).

Under this doctrine, if Congress intends to alter the balance between federal and state authority, it is required to make an unmistakably clear statement to that effect.