Department of Commerce v. United States House of Representatives — Quick Summary

Department of Commerce v. United States House of Representatives

525 U.S. 316 (1999)

In Brief

The case of Department of Commerce v. United States House of Representatives holds significant importance in the realm of Constitutional and administrative law, for it addresses the acceptable means by which the United States Census may be conducted.

Key Issue

Is the use of statistical sampling in the decennial census for the purpose of apportioning seats in the United States House of Representatives consistent with the Census Act and the Constitution?

The Rule

According to the Census Act, particularly 13 U.S.C. §§ 141 and 195, and Article I, Section 2 of the U.S. Constitution, the decennial census must be an 'actual Enumeration' for the purposes of apportioning seats among the states, implying a requirement for, at a minimum, direct headcount enumeration.

Bottom Line

The Supreme Court held that the Census Act prohibits the use of statistical sampling for purposes of congressional apportionment, affirming the lower court's decision.

Why It Matters

This case is significant as it delineates the limits of administrative discretion in executing a constitutionally mandated event. For law students, it provides a clear example of statutory interpretation, especially regarding oversight during administrative implementation of complex constitutional provisions. It also illustrates the intersection of modern statistical techniques with traditional legal mandates, emphasizing how legislatures and courts adapt to technological and methodological advancements.

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