"How do you count, with accuracy, 275 million mobile people? That is the task of the U.S. Census Bureau in the year 2000. Unfortunately, the courts rather than the professionals have made this decision.
"On January 25, 1999, in the case of Department of Commerce v. United States House of Representatives, No. 98-404, the nation's highest court ruled that statistical sampling of the population for the next census in the year 2000 cannot be used to apportion seats to the house of Representatives."
Smolski, Chester, "Population Sampling Issue Still Bedevils" (1999). Smolski Texts. 283.