''Utah v. Evans'', 536 U.S. 452 (2002), was a

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

case holding that the use of certain statistical techniques in the United States Census does not violate 13 USC §195 or the Census Clause of the Constitution. In instances where the

Census Bureau The United States Census Bureau (USCB), officially the Bureau of the Census, is a principal agency of the Federal Statistical System of the United States, U.S. Federal Statistical System, responsible for producing data about the Americans, Ame ...

remained unsure of the number of residents at an address after a field visit, the Bureau inferred its population characteristics with statistics taken from its nearest similar neighbor, a practice called " hot-deck imputation." The use of hot-deck imputation in the 2000 Census increased the population of

North Carolina North Carolina () is a state in the Southeastern region of the United States. The state is the 28th largest and 9th-most populous of the United States. It is bordered by Virginia to the north, the Atlantic Ocean to the east, Georgia and ...

0.4% and

Utah Utah ( , ) is a state in the Mountain West subregion of the Western United States. Utah is a landlocked U.S. state bordered to its east by Colorado, to its northeast by Wyoming, to its north by Idaho, to its south by Arizona, and to it ...

by 0.2%. Due to the practice, during the reapportionment of the

US House of Representatives The United States House of Representatives, often referred to as the House of Representatives, the U.S. House, or simply the House, is the lower chamber of the United States Congress, with the Senate being the upper chamber. Together they ...

Utah received one less seat and North Carolina gained a seat. Utah sought an injunction requiring the Bureau to revise the published census results to those without the use of imputation. North Carolina, which stood to lose a Representative under such an injunction, intervened in the case, disputing Utah's

standing Standing, also referred to as orthostasis, is a position in which the body is held in an ''erect'' ("orthostatic") position and supported only by the feet. Although seemingly static, the body rocks slightly back and forth from the ankle in the s ...

to sue. The Utah federal district court refused to grant the State's injunction ruling in favor of the Census Bureau. Appealing the ruling to the Supreme Court, Utah argued that the Bureau's use of imputation violated 13 U.S.C. §195, which prohibits use of ' sampling' for apportioning Representatives among states. It further argued that imputation did not satisfy the United States Constitution's requirement of an "actual enumeration" for the purpose of apportioning Representatives. In an 8–1 ruling, the Supreme Court rejected Utah's arguments and affirmed the district court's opinion. In the majority opinion

Justice Breyer Stephen Gerald Breyer ( ; born August 15, 1938) is a retired American lawyer and jurist who served as an associate justice of the U.S. Supreme Court from 1994 until his retirement in 2022. He was nominated by President Bill Clinton, and rep ...

reasoned that hot-deck imputation did not constitute sampling, which attempts to extrapolate statistics about a large population from the statistics of a smaller one, rather it attempts to account for missing individuals by comparing across populations. Furthermore, the Census Clause of the Constitution was not violated as the actual enumeration needs to be conducted "in such Manner as" Congress itself "shall by Law direct," which wording which does not forbid the use of statistical methods to improve accuracy.

External links

* United States Supreme Court cases United States electoral redistricting case law 2002 in United States case law United States Census Bureau Congressional districts of Utah United States Supreme Court cases of the Rehnquist Court {{SCOTUS-case-stub

See also

External links