A top executive at the survey firm Nielsen said in a court affidavit that the Commerce Department mischaracterized a conversation she had with Secretary Wilbur Ross about adding a citizenship question to the census — a conversation he later referenced in a memo justifying the question.
The affidavit, filed Tuesday by Nielsen senior vice president of data science Christine Pierce, picks apart both that memo, and internal notes written to document their March 23 conversation.
The internal notes were made public in the court cases challenging the addition of the citizenship question, as part of the administrative record that the Commerce Department says shows that it followed the law in the process it used to add the question.
A Commerce spokesperson argued in a statement to TPM that the affidavit “actually confirms the accuracy of statements Secretary Ross” in the memo announcing the addition of the question.
“[M]edia distortions to the contrary are flatly false,” the spokesperson said. “The Affidavit—produced on the eve of trial—is another attempt by Plaintiffs to try their distorted case in the media, rather than in court, where facts ought to matter.”
The March 26 public memo said that Pierce and other experts had “confirmed that, to the best of their knowledge, no empirical data existed on the impact of a citizenship question on responses.”
Pierce’s affidavit says that she did not say that, but rather that she “explained that a lack of testing could lead to poor survey results.”
The public memo also attributed to Nielsen a claim that when the firm had added questions on “sensitive topics such as place of birth and immigration status,” taken from the same smaller scale census survey that had previously asked a citizenship question, there had been no “appreciable decrease in response rates.”
Pierce’s affidavit says the she did not say that, but rather in her conversation stressed that there had been significant testing on those questions before they were added to the Nielsen surveys
The affidavit said that Pierce was not aware of the Commerce Department asking for Nielsen documents related to the firm’s survey work or question testing.
When it comes to the internal notes about their conversation, Pierce says that she did not say, as the notes claimed, “that including a question on citizenship could make people less likely to respond, but that there is no data to predict how much lower the response rate might be.”
She rebutted the claim that she had “noted that in the only specific situation she was aware of that sensitive questions were tested on a short questionnaire, there was no impact on response rates.”
The call was arranged while Ross was taking input from stakeholders on whether he should add the citizenship question. Pierce says she was taken off guard by the topic of the 10- to 20-minute conversation, as she, while arranging the call with Ross’ staff, was never told the conversation was about the citizenship question specifically, but rather the importance of the census more generally.
Her affidavit comes after Science Magazine had reported that the public memo didn’t fully represent her conversation with Ross.
Read the affidavit: