Utah v. Evans
|Utah v. Evans|
|Argued March 27, 2002|
Decided June 20, 2002
|Full case name||Utah, et al. v. Evans, Secretary of Commerce, et al.|
|Citations||536 U.S. 452 (more)|
|Prior||Utah sought an injunction compelling respondents to change the official census results. North Carolina intervened. The District Court for the District of Utah found for the Census Bureau|
|Utah had standing to sue for a revision of the census results. The Bureau's use of hot-deck imputation did not violate 13 USC sec. 195, nor the census clause of the Constitution.|
|Majority||Breyer, joined by Rehnquist, Stevens, Souter, Ginsburg; O'Connor (Parts I and II)|
|Concur/dissent||Thomas, joined by Kennedy|
|13 U.S.C. § 195, U.S. Const., Art. I, section 2, clause 3|
In instances where the Census Bureau remained unsure of the number of residents at an address after a field visit, the Bureau inferred its population characteristics from its nearest similar neighbor, a practice called "hot-deck imputation." In the reapportionment after the 2000 census, hot-deck imputation resulted in Utah receiving one less Representative in Congress than it would have without the practice. Utah sought an injunction requiring the Bureau to revise the census results 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 to sue. The Utah federal district court refused to grant the injunction.
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. The Supreme Court rejected Utah's arguments and affirmed the district court's opinion.
- Text of Utah v. Evans, 536 U.S. 452 (2002) is available from: Google Scholar Justia Oyez (oral argument audio)
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