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Utah v. Evans

Utah v. Evans, 536 U.S. 452 (2002), was a United States Supreme Court 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. The case was brought against Donald L. Evans, et al. by the state of Utah;[1][2] Evans was the U.S. Secretary of Commerce at the time.[3]

Utah v. Evans
Argued March 27, 2002
Decided June 20, 2002
Full case nameUtah, et al. v. Evans, Secretary of Commerce, et al.
Citations536 U.S. 452 (more)
122 S. Ct. 2191; 153 L. Ed. 2d 453; 2002 U.S. LEXIS 4645; 70 U.S.L.W. 4628; 2002 Cal. Daily Op. Service 5474; 2002 Daily Journal DAR 6881; 15 Fla. L. Weekly Fed. S 420
Case history
PriorUtah 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
Holding
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.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajorityBreyer, joined by Rehnquist, Stevens, Souter, Ginsburg; O'Connor (Parts I and II)
Concur/dissentO'Connor
Concur/dissentThomas, joined by Kennedy
DissentScalia
Laws applied
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 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 by 0.4% and Utah by 0.2%. Due to the practice, during the reapportionment of the US House of Representatives 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 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 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.

This case follow several others that rule on 'sampling' in the US census, including Department of Commerce v. United States House of Representatives, 525 U.S. 316 (1999), a suit which followed President Clinton's veto of a law passed by Congress intending to explicitly prohibit sampling, and Wisconsin v. City of New York, 517 U.S. 1 (1996), which ruled that sampling was not required by the Enumeration clause.

See also edit

References edit

  1. ^ Utah v. Evans (2002), Text.
  2. ^ "UTAH v. EVANS".
  3. ^ "Secretaries of Commerce".

External links edit

  • Text of Utah v. Evans, 536 U.S. 452 (2002) is available from: Google Scholar  Justia  Oyez (oral argument audio) 


utah, evans, 2002, united, states, supreme, court, case, holding, that, certain, statistical, techniques, united, states, census, does, violate, census, clause, constitution, case, brought, against, donald, evans, state, utah, evans, secretary, commerce, time,. Utah v Evans 536 U S 452 2002 was a United States Supreme Court 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 The case was brought against Donald L Evans et al by the state of Utah 1 2 Evans was the U S Secretary of Commerce at the time 3 Utah v EvansSupreme Court of the United StatesArgued March 27 2002Decided June 20 2002Full case nameUtah et al v Evans Secretary of Commerce et al Citations536 U S 452 more 122 S Ct 2191 153 L Ed 2d 453 2002 U S LEXIS 4645 70 U S L W 4628 2002 Cal Daily Op Service 5474 2002 Daily Journal DAR 6881 15 Fla L Weekly Fed S 420Case historyPriorUtah 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 BureauHoldingUtah 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 Court membershipChief Justice William Rehnquist Associate Justices John P Stevens Sandra Day O ConnorAntonin Scalia Anthony KennedyDavid Souter Clarence ThomasRuth Bader Ginsburg Stephen BreyerCase opinionsMajorityBreyer joined by Rehnquist Stevens Souter Ginsburg O Connor Parts I and II Concur dissentO ConnorConcur dissentThomas joined by KennedyDissentScaliaLaws applied13 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 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 by 0 4 and Utah by 0 2 Due to the practice during the reapportionment of the US House of Representatives 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 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 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 This case follow several others that rule on sampling in the US census including Department of Commerce v United States House of Representatives 525 U S 316 1999 a suit which followed President Clinton s veto of a law passed by Congress intending to explicitly prohibit sampling and Wisconsin v City of New York 517 U S 1 1996 which ruled that sampling was not required by the Enumeration clause See also editList of United States Supreme Court cases volume 536 List of United States Supreme Court casesReferences edit Utah v Evans 2002 Text UTAH v EVANS Secretaries of Commerce External links editText of Utah v Evans 536 U S 452 2002 is available from Google Scholar Justia Oyez oral argument audio nbsp This article related to the Supreme Court of the United States is a stub You can help Wikipedia by expanding it vte Retrieved from https en wikipedia org w index php title Utah v Evans amp oldid 1212595137, wikipedia, wiki, book, books, library,

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