Passel, Jeffrey S., and Karen A. Woodrow. 1984. “The Judicial Basis for Enumeration of Undocumented Aliens in the 1980 Census and Implications for 1990,” 1984 Proceedings of the American Statistical Association, Social Statistics Section, pp. 464 469.

The 1980 census included 2.1 million undocumented residents who were geographically concentrated in California, New York, Texas, Illinois, and Florida. This paper reviews the FAIR lawsuit filed in late 1979, explains the judicial basis for enumerating residents without regard to lawful status, and addresses the implications of inclusion of estimated undocumented populations for apportionment of congressional representation among the states. Hypothetically, the presence of undocumented residents may have contributed to gains of a congressional seat each for California and New York and losses of a congressional seat each for Georgia and Indiana. The precise impacts cannot be specified because estimates of undocumented populations are not sufficiently precise.