Census Bureau explicitly includes both legal non-
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legal non-citizen and undocumented
residents in the census.
Thus the more seats in legislatures.
In our era of historically high immigration, this has a major impact on legislative apportionment because these immigrants are very unevenly distributed. The Census Bureau estimates that the proportion of non-citizen population in the states varies from 14% in California to less than 1% in West Virginia. This has a direct impact on the states’ political power. California, on its way to becoming the first sanctuary state, has five or six more members of the House (and consequently Electoral College votes) counting its non-citizen population than if House seats and Electoral College votes were based on only citizen population. No wonder California politicians favor illegal immigration.