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Keywords

plaintiffinjunctiontrialdue processcitizenshipbench trial

plaintiffdue processcitizenship

Related Cases

New York v. United States Department of Commerce, 351 F.Supp.3d 502

Facts

A coalition of states, the District of Columbia, local governmental entities, and non-governmental organizations (NGOs) challenged the Secretary of Commerce's decision to include a citizenship question on the 2020 census questionnaire. They argued that this decision violated the Administrative Procedure Act (APA), the Constitution's Enumeration Clause, and the Fifth Amendment's Due Process Clause. The plaintiffs contended that the inclusion of the question would lead to a significant undercount of noncitizen households, affecting federal funding and political representation. After a bench trial, the court found that the Secretary's decision was arbitrary and capricious and violated the Census Act.

The plaintiffs contended that the inclusion of question would harm their core missions of advancing interests, and enhancing political power, of communities they served, and that Secretary's decision caused them divert organizational resources away from their core missions and towards combating question's negative effects.

Issue

Did the Secretary of Commerce's decision to include a citizenship question on the 2020 census questionnaire violate the Administrative Procedure Act, the Enumeration Clause of the Constitution, and the Due Process Clause of the Fifth Amendment?

Rule

The Administrative Procedure Act (APA) requires that agencies consider all important aspects of a problem, study relevant evidence, and arrive at a decision that is rationally supported by that evidence. The Constitution mandates that the federal government conduct a decennial census counting all persons residing in each state, without reference to citizenship status. The Secretary of Commerce must use administrative record data instead of conducting direct surveys whenever possible, and if surveys are conducted, statistical sampling should be used.

Analysis

The court analyzed the Secretary's decision under the APA and found that he failed to consider important aspects of the problem, including the accuracy of administrative records compared to self-responses. The Secretary's rationale for including the citizenship question was deemed pretextual, as he did not adequately justify the decision based on the evidence available. The court also noted that the inclusion of the question would likely lead to a significant undercount of noncitizen households, which would affect federal funding and representation.

Conclusion

The court held that the Secretary's decision to include the citizenship question on the 2020 census questionnaire was arbitrary and capricious, violating the APA and the Census Act. The appropriate remedy was vacatur and remand, along with a nationwide injunction against the inclusion of the question.

Who won?

The coalition of states, local governments, and NGOs prevailed in their challenge against the Secretary of Commerce's decision. The court found that the Secretary's inclusion of the citizenship question was not only arbitrary and capricious but also violated statutory requirements under the Census Act. The ruling emphasized the importance of an accurate census for federal funding and political representation, highlighting the potential harm to communities if the question led to an undercount.

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