What's your legal basis for that though? The Constitution specifies that House apportionment counts everyone, not just citizens.
"Representatives and direct Taxes shall be apportioned among the several States which may be included within this Union, according to their respective Numbers, which shall be determined by adding to the whole Number of free Persons, including those bound to Service for a Term of Years, and excluding Indians not taxed, three fifths of all other Persons. "
Slaves were specifically counted at 3/5s. But free noncitizens were always counted and at full. The Constitution uses 'citizen' all the time, and specifically used 'free Persons' here instead.