Utah v. Evans
Utah v. Evans, 536 U.S. 452
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...

 (2002), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 case regarding the use of certain statistical techniques in the census
United States Census
The United States Census is a decennial census mandated by the United States Constitution. The population is enumerated every 10 years and the results are used to allocate Congressional seats , electoral votes, and government program funding. The United States Census Bureau The United States Census...


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
Imputation (statistics)
In statistics, imputation is the substitution of some value for a missing data point or a missing component of a data point. Once all missing values have been imputed, the dataset can then be analysed using standard techniques for complete data...

." In the 2000 census, hot-deck imputation resulted in Utah receiving one less Representative in Congress than it would have without the practice. Utah
Utah is a state in the Western United States. It was the 45th state to join the Union, on January 4, 1896. Approximately 80% of Utah's 2,763,885 people live along the Wasatch Front, centering on Salt Lake City. This leaves vast expanses of the state nearly uninhabited, making the population the...

 sought an injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...

 requiring the Bureau to revise the census results without the use of imputation. North Carolina
North Carolina
North Carolina is a state located in the southeastern United States. The state borders South Carolina and Georgia to the south, Tennessee to the west and Virginia to the north. North Carolina contains 100 counties. Its capital is Raleigh, and its largest city is Charlotte...

, which stood to lose a Representative under such an injunction, intervened in the case, disputing Utah's standing
Standing (law)
In law, standing or locus standi is the term for the ability of a party to demonstrate to the court sufficient connection to and harm from the law or action challenged to support that party's participation in the case...

 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
United States Constitution
The Constitution of the United States is the supreme law of the United States of America. It is the framework for the organization of the United States government and for the relationship of the federal government with the states, citizens, and all people within the United States.The first three...

'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.

See also

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