[What follows below is the substance of a document Miss Silva prepared, which was filed on June 6, 1961, with the U. S. District Court for the Southern District of New York, as an Appendix to the petitioners' complaint in the case of W.M.C.A., Inc. et al. v. Caroline K. Simon, Secretary of the State of New York, et al. (61 Civil No. 1559, 1961). The suit seeks declaratory and injunctive relief and alleges that the apportionment and districting provisions of the New York Constitution deny the petitioners and others similarly situated both due process and the equal protection of the laws, contrary to the Fourteenth Amendment of the federal constitution. Miss Silva had been employed in 1959–60 as special consultant on legislative apportionment by the State of New York Temporary Commission on Revision and Simplification of the Constitution, which reproduced in two volumes as Staff Report No. 33 (April, 1960) the study she made for it.

Litigation in the federal courts concerning legislative apportionments, from Colegrove v. Green, 328 U.S. 549 (1946) to Baker v. Carr, the Tennessee case pending in the Supreme Court at this writing, has been largely preoccupied with questions of federal jurisdiction. The document below does not touch this issue, but rather is confined to the practical effects of the apportionment and districting provisions of the New York Constitution. Man. Ed.]