Utah is pretty much guaranteed a fourth seat following the 2010 Census, according to population projections.

But those same projections show there's a chance the same issues that prevented the Beehive State from getting an additional seat in Congress in 2000 could resurface in 2020.

That's because of the narrow margin by which Utah, based on population growth projections, is expected to earn the seat, said Robert Spendlove, manager of demographic and economic analysis for the Governor's Office of Planning and Budget.

"In 2010, it's virtually impossible for Utah to not get a fourth seat," Spendlove said. "It's a 2020 issue.

"Every state has at least one seat," Spendlove said. "The seats from 51st to 435th are ranked. The question is, what is the rank."

In 2020, Utah's population is projected to near 3.5 million. That would rank the state 434th, just enough to qualify for a seat. But just behind Utah — by a fraction of a percent — would be Oregon and Virginia.

"We have confidence in the projections we produce," Spendlove said. "However, this is 15 years away and there is a wide margin of error ... when you're talking about tenths of a percent."

In 2000, Utah fell short of a fourth seat by just 859 people, and a counting error discovered later narrowed that gap to 80 people. The seat instead went to North Carolina.

Utah said the count was unfair because thousands of overseas LDS Church missionaries from Utah weren't counted, and also because of an estimation method the state called unfair.

However, even without those issues, Utah still may not grow enough by 2020 to earn an additional seat, said Pam Perlich, senior research economist at the University of Utah.

"Other states that are larger are gaining more," Perlich said. "We're not a big state."

Since the 2000 count, Utah has unsuccessfully tried to gain the fourth seat through court challenges, and more recently legislation.

The legislation, which appears stalled, would have added two seats to Congress — one for Utah and another for Washington, D.C.

The state also launched two unsuccessful court challenges. One claimed that by counting military personnel and federal employees living overseas, but not LDS missionaries, the Census Bureau gave an unfair advantage to North Carolina, which has a large military population.

A second challenge, which was argued before the U.S. Supreme Court, claimed the bureau used flawed methodology to estimate the population of households that appeared occupied but no residents could be found.

Utah Assistant Attorney General Ray Hintze said the state believed the method accounted to sampling akin to that which the Supreme Court had previously overturned. However, in this case the high court sided with the bureau.