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However, Ford said this would have been a wildly inaccurate way to try to estimate the undocumented immigrant population because some people in ICE detention facilities are ultimately found to be in the country lawfully.The memo itself acknowledges this issue in the “cons” section by suggesting that it would have to be assumed "that either all prisoners living in the detention centers are here illegally or some proportion.” It also acknowledged that the number of undocumented immigrants in the facilities would be on the “lower-end” of “actually illegal people.”Another option would have relied on data from the American Community Survey, known as the “long-form” census, which collects demographic data annually from roughly 3 percent of households in the U.S. However, in 1999 the U.S. Supreme Court rejected the Census Bureau’s proposed uses of statistical sampling, such as the methods used on the ACS, to calculate the population for purposes of congressional apportionment.
As said here by https://www.nbcnews.com/politics/politics-news/internal-document-reveals-trump-admin-strategies-omit-undocumented-immigrants-census-n1267395