Wisconsin v. City of New York
Distributive Accuracy Versus Actual Accuracy
The Supreme Court unanimously reversed the decision of the court of appeals. Once again, the need for accuracy in the taking of the census was crucial to the decision. Whereas the court of appeals ruled that a deliberate undercount effectively deprived individuals of their right to vote, the Supreme Court held that the census was distinct from the electoral process. Writing for the Court, Justice Rehnquist noted that the Constitution mandates that a census be taken every ten years, and that it be conducted by Congress "in such Manner as they shall by Law direct." Furthermore, the Court believed that the constitutional intent of the census was to insure the "distributive accuracy" of population counts among the states to determine their relative representation in Congress, as opposed to actual accuracy of population counts within each state. Since the same method was applied to each state, the known undercount would be nearly the same for each state and the distributive accuracy of the census would remain the same regardless of the method used. As such, the secretary's decision not to use post-enumeration surveys and DSE procedures was judged to be reasonable and to adhere to constitutional standards.
Additional topics
Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1995 to PresentWisconsin v. City of New York - Decision, An Early Constitutional Compromise, Census Procedures And Statistical And Demographic Advances, The 1990 Census