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It goes back to slavery days and, you know, what portion of a person is going to be counted, et cetera. Here, of course, he was referring to the notorious Three-Fifths Compromise, reached between Northern and Southern states at the 1787 Constitutional Convention, under which only three-fifths of a states enslaved population counted for apportionment and taxation purposes (all enslaved individuals were still included in the federal census, even if in an odious way, as legal scholar Steve Vladeck put it)

But as with all research, there are issues