ACLU 2020 Census State Administrative Records Comment

The ACLU submitted this comment highlighting our serious concerns about the Census Bureau’s plans to expand the collection of state administrative record data including by collecting person-level citizenship information. This collection appears intended to support the Bureau’s planned release of block-level citizenship voting-age population (“CVAP”) data product part of the 2020 Census Redistricting Data Program, widely understood to be part of an effort to dilute Latino political power by allowing states to redistrict using CVAP only. The ACLU reiterates our opposition to the Census Bureau’s facilitation of racially and politically motivated redistricting efforts through the creation of such a CVAP data product, and urges the Bureau to abandon efforts to collect person-level citizenship data from state administrative records given the well-known unreliability of state administrative records regarding citizenship status as recently illustrated in Texas and Kansas. There has also been a concerning lack of transparency and details from the Bureau about how it plans to expand its collection of state administrative records and how it will use any citizenship data collected through this process to create the proposed CVAP product.