Utah v. Evans

Background

The State of Utah sued census officials after the 2000 census, challenging a Bureau process called "hot-deck imputation." The Bureau used three forms of imputation (status, occupancy, and household-size) to fill missing or conflicting address information. Imputation added about 1.2 million people, roughly 0.4% of the total, and the parties agreed that the difference shifted one House seat to North Carolina and away from Utah. The District Court ruled for the Bureau and Utah appealed.

Reasoning

The Court addressed two questions: whether imputation is the banned "statistical method known as 'sampling'" and whether it violates the Constitution's command of an "actual Enumeration." Relying on technical definitions, the Bureau's long practice and explanations, and statutory history, the majority concluded imputation differs from sampling in nature, method, and objective. The Court also found Utah had standing, following Franklin v. Massachusetts, and thus had jurisdiction to decide the case. The Court affirmed the District Court: imputation violated neither the sampling statute nor the Census Clause.

Real world impact

The ruling leaves the 2000 apportionment in place (North Carolina gains a seat; Utah loses one) and allows limited use of hot-deck imputation as a last-resort way to fill gaps after follow-up efforts. The majority emphasized that imputation was used sparingly after other efforts failed and constituted a small percentage of the count. The Court signaled that future abuses or different methods could be addressed later.

Dissents or concurrances

Justice O'Connor would have treated imputation as prohibited sampling and would have reversed on that statutory ground. Justice Thomas argued imputation conflicts with the original meaning of the Census Clause and is unconstitutional. Justice Scalia argued the plaintiffs lacked Article III standing. These separate opinions focused on statutory interpretation, original history, and standing respectively.