The Framers of the American Constitution viewed the decennial census as providing a certain rhythm to American politics. Every ten years a state's tax burdens and representation in the House of Representatives would change to reflect its share of the national population as revealed in the "actual enumeration," the manner of which Congress "shall by law direct." ¹ Much has changed since the first census, but the rhythm still remains. Perhaps unintended and unimagined by the Framers, however, is the rhythmic and ritualistic dance to the courtroom every ten years to argue over the census numbers themselves and the methods used to construct apportionment totals.