In Utah v. Evans, the majority decided that the US Census can use statistical estimation to count households that cannot be easily reached. The Census Bureau uses the euphemism imputation instead of estimation or extrapolation.
Judge Breyer writes that the Census Bureau is not bound by the term "actual Enumeration" in the US Constitution. Here are his stated reasons:
The argument in incoherent and innumerate. The term "actual Enumeration" is there for its obvious meaning. Removing the "imputation" would make the result more accurate, not less, because it would make the count closer to the "actual Enumeration" that the Constitution requires.
As usual, it is Judge Thomas whose stinging dissent is dead-on correct.