2002 United States Supreme Court case
Utah v. Evans 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] U.S. Secretary of Commerce at the time.[ 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
References
External links
Equal population Partisan gerrymandering Racial gerrymandering Other
Dormant Commerce Clause
Brown v. Maryland Willson v. Black-Bird Creek Marsh Co. Cooley v. Board of Wardens Wabash, St. Louis & Pacific Railway Co. v. Illinois Swift & Co. v. United States George W. Bush & Sons Co. v. Malloy Baldwin v. G.A.F. Seelig, Inc. Edwards v. California Southern Pacific Co. v. Arizona Dean Milk Co. v. City of Madison Miller Bros. Co. v. Maryland Bibb v. Navajo Freight Lines, Inc. National Bellas Hess v. Illinois Pike v. Bruce Church, Inc. Hughes v. Alexandria Scrap Corp. Complete Auto Transit, Inc. v. Brady Hunt v. Washington State Apple Advertising Commission City of Philadelphia v. New Jersey Exxon Corp. v. Governor of Maryland Reeves, Inc. v. Stake Kassel v. Consolidated Freightways Corp. Sporhase v. Nebraska ex rel. Douglas White v. Mass. Council of Construction Employers South-Central Timber Development, Inc. v. Wunnicke Maine v. Taylor Healy v. Beer Institute, Inc. Quill Corp. v. North Dakota Chemical Waste Management, Inc. v. Hunt Oregon Waste Systems, Inc. v. Department of Environmental Quality of Oregon C&A Carbone, Inc. v. Town of Clarkstown West Lynn Creamery, Inc. v. Healy Granholm v. Heald United Haulers Ass'n v. Oneida-Herkimer Solid Waste Management Authority Department of Revenue of Kentucky v. Davis Comptroller of the Treasury of Maryland v. Wynne South Dakota v. Wayfair, Inc. Tennessee Wine and Spirits Retailers Assn. v. Thomas National Pork Producers Council v. Ross Others
Copyright Act of 1790 Patent Act of 1793 Patent infringement case lawPatentability case lawCopyright Act of 1831 Copyright Act of 1870 Sherman Antitrust Act of 1890 International Copyright Act of 1891 Copyright Act of 1909 Patent misuse case lawClayton Antitrust Act of 1914 Lanham Act
Inwood Laboratories, Inc. v. Ives Laboratories, Inc. San Francisco Arts & Athletics, Inc. v. United States Olympic Committee Two Pesos, Inc. v. Taco Cabana, Inc. Qualitex Co. v. Jacobson Products Co. College Savings Bank v. Florida Prepaid Postsecondary Education Expense Board Cooper Industries, Inc. v. Leatherman Tool Group, Inc. TrafFix Devices, Inc. v. Marketing Displays, Inc. Dastar Corp. v. Twentieth Century Fox Film Corp. Moseley v. V Secret Catalogue, Inc. Lexmark International, Inc. v. Static Control Components, Inc. POM Wonderful LLC v. Coca-Cola Co. Matal v. Tam Iancu v. Brunetti Romag Fasteners, Inc. v. Fossil, Inc. Copyright Act of 1976
Zacchini v. Scripps-Howard Broadcasting Co. Sony Corp. of America v. Universal City Studios, Inc. Mills Music, Inc. v. Snyder Harper & Row v. Nation Enterprises Community for Creative Non-Violence v. Reid Stewart v. Abend Feist Publications, Inc., v. Rural Telephone Service Co. Fogerty v. Fantasy, Inc. Campbell v. Acuff-Rose Music, Inc. Lotus Dev. Corp. v. Borland Int'l, Inc. Quality King Distributors Inc., v. L'anza Research International Inc. Feltner v. Columbia Pictures Television, Inc. New York Times Co. v. Tasini Eldred v. Ashcroft MGM Studios, Inc. v. Grokster, Ltd. Reed Elsevier, Inc. v. Muchnick Golan v. Holder Kirtsaeng v. John Wiley & Sons, Inc. Petrella v. Metro-Goldwyn-Mayer, Inc. American Broadcasting Cos., Inc. v. Aereo, Inc. Star Athletica, LLC v. Varsity Brands, Inc. Fourth Estate Public Benefit Corp. v. Wall-Street.com Rimini Street Inc. v. Oracle USA Inc. Allen v. Cooper Georgia v. Public.Resource.Org, Inc. Other copyright cases Other patent cases
Continental Paper Bag Co. v. Eastern Paper Bag Co. Minerals Separation, Ltd. v. Hyde United States v. General Electric Co. United States v. Univis Lens Co. Altvater v. Freeman Sinclair & Carroll Co. v. Interchemical Corp. Funk Bros. Seed Co. v. Kalo Inoculant Co. Great Atlantic & Pacific Tea Co. v. Supermarket Equipment Corp. Graver Tank & Manufacturing Co. v. Linde Air Products Co. Aro Manufacturing Co. v. Convertible Top Replacement Co. Compco Corp. v. Day-Brite Lighting, Inc. Wilbur-Ellis Co. v. Kuther Brulotte v. Thys Co. Walker Process Equipment, Inc. v. Food Machinery & Chemical Corp. Graham v. John Deere Co. United States v. Adams Brenner v. Manson Lear, Inc. v. Adkins Anderson's-Black Rock, Inc. v. Pavement Salvage Co. Zenith Radio Corp. v. Hazeltine Research, Inc. Gottschalk v. Benson United States v. Glaxo Group Ltd. Dann v. Johnston Sakraida v. Ag Pro Inc. Parker v. Flook Diamond v. Chakrabarty Diamond v. Diehr Bonito Boats, Inc. v. Thunder Craft Boats, Inc. Eli Lilly & Co. v. Medtronic, Inc. Markman v. Westview Instruments, Inc. Warner-Jenkinson Co. v. Hilton Davis Chemical Co. Pfaff v. Wells Electronics, Inc. Dickinson v. Zurko Florida Prepaid Postsecondary Education Expense Board v. College Savings Bank J. E. M. Ag Supply, Inc. v. Pioneer Hi-Bred International, Inc. Festo Corp. v. Shoketsu Kinzoku Kogyo Kabushiki Co. Merck KGaA v. Integra Lifesciences I, Ltd. eBay Inc. v. MercExchange, L.L.C. Illinois Tool Works Inc. v. Independent Ink, Inc. LabCorp v. Metabolite, Inc. MedImmune, Inc. v. Genentech, Inc. KSR International Co. v. Teleflex Inc. Microsoft Corp. v. AT&T Corp. Quanta Computer, Inc. v. LG Electronics, Inc. Bilski v. Kappos Global-Tech Appliances, Inc. v. SEB S.A. Stanford University v. Roche Molecular Systems, Inc. Microsoft Corp. v. i4i Ltd. Partnership Mayo Collaborative Services v. Prometheus Laboratories, Inc. Kappos v. Hyatt Bowman v. Monsanto Co. Gunn v. Minton Association for Molecular Pathology v. Myriad Genetics, Inc. FTC v. Actavis, Inc. Alice Corp. v. CLS Bank International Akamai Techs., Inc. v. Limelight Networks, Inc. Teva Pharmaceuticals USA, Inc. v. Sandoz, Inc. Kimble v. Marvel Entertainment, LLC Apple Inc. v. Samsung Electronics Co. TC Heartland LLC v. Kraft Foods Group Brands LLC Peter v. NantKwest, Inc. Other trademark cases
You must be logged in to post a comment.