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Having used statistical techniques to adjust the population coun <br />overcounts, the Census Bureau, shortly before the release of the <br />decided not to release the adjusted counts, saying it was not co <br />courts upheld the decision of the Bureau not to release the adju Carter v. U.S. <br />th <br />Department of Commerce,No. 02-35161, 307 F.3d 1084 (9 Cir. 2002). <br />The Census Bureau has not proposed any statistical adjustment to <br />3.Exclusion of Undocumented Aliens <br />The census is not limited to citizens. It is not even limited t <br />constitution says to count “persons,” Art. I, § 2, as amended by the Fourteenth Amendment, so even <br />homeless people are counted where they usually sleep. <br />Pennsylvania and other states have sought without success to req <br />exclude undocumented aliens from the population counts used to a <br />among the states. See Ridge v. Verity, 715 F. Supp. 1308 (W.D. Pa. 1989); Federation for American <br />Immigration Reform (FAIR) v. Klutznick, 486 F. Supp. 564 (D.D.C. 1980, appeal dismissed, 447 <br />U.S. 916 (1980). <br />4.Inclusion of Overseas Military Personnel <br />In 1990, the Department of Defense conducted a survey of its ove <br />employees and their dependents to determine their “address of re <br />personnel were allocated to the states according to their addres <br />apportioning the House of Representatives, but were not included <br />given to the states for use in redistricting. Allocating oversea <br />one congressional seat to be shifted from Massachusetts to Washi <br />the Secretary of Commerce, but the Supreme Court upheld the allo Franklin v. <br />Massachusetts,505 U.S. 788 (1992). <br />B.Census Geography <br />1.Public Law 94-171 <br />When a state receives its official Census Bureau population coun <br /> What each state gets depends on what it asked for. <br />Public Law 94-171, 89 Stat. 1023 (1975) (codified as amended at 13 U.S.C. § 141(c)), <br />permits each state to request the Census Bureau to provide it wi <br />accordance with the geographic areas identified by the state and <br />counts before April 1, 2011. These counts are often referred to <br />9 <br /> <br />