Federal judge blocks enforcement of Ohio proof-of-citizenship requirement for voter registration

COLUMBUS, Ohio (AP) — A federal judge on Tuesday temporarily blocked enforcement of an Ohio requirement that voters show proof of citizenship when registering to vote at a motor vehicle bureau, a rule that took effect for the first time this year.

Secretary of State Frank LaRose, a Republican, said he would immediately appeal.

In a lawsuit brought on behalf of the Ohio Alliance of Retired Americans and the progressive group Red Wine & Blue by the Democrat-aligned Elias Law Group, U.S. District Court Judge Solomon Oliver Jr. in Cleveland ruled that the requirement appears to conflict with the National Voter Registration Act, which he said takes precedence.

His injunction suspends the practice of requiring such documentation ahead of the Oct. 5 registration deadline for this fall’s midterm elections.

It comes as President Donald Trump pushes Congress to pass a bill that would, among other election changes, require documentary proof of citizenship to register to vote.

Ohio is among a handful of states with proof-of-citizenship laws in place for the first time this year . South Dakota, Utah and Wyoming also put similar requirements on the books for this year's midterms. Arizona had one already in force for state and local elections.

In South Dakota on Tuesday, the League of Women Voters and a Sioux Falls voter filed a lawsuit over that state’s new proof-of-citizenship requirement for voter registration. Among their requests is that a judge force the state to accept photocopies of eligible ID forms and also to rescind guidance requiring people using certain ID types to register in person.

Ohio's requirement was added last year to its motor voter law. In his ruling, Solomon wrote that the requirement “is more than the signed attestation to U.S. citizenship that Ohio’s other voter registration methods accept. Therefore, (the challenged provision) likely conflicts with the NVRA, because it is more than ‘the minimum amount of information necessary.’”

He further found that Ohio's overall “motor voter” registration process has illegally been limiting the option to sign up to vote to those who successfully obtain a driver's license, rather than offering it to everyone who submits an application for one, as federal law requires.

Ben Stafford, a partner at Elias Law, said in a statement that Ohio voters would now be able to register at the BMV without the requirement to show citizenship paperwork. He described the regulation as “exactly the type of government-imposed barrier that the NVRA exists to prevent.”

The judge's order prevents Ohio from requiring any driver’s license applicant to produce proof-of-citizenship documents before being offered the chance to register to vote, even those applicants turned away for lack of the proper paperwork. It doesn't cover applicants who indicate they are not U.S. citizens.

LaRose criticized the ruling and pointed to a case in Franklin County, which includes Columbus, that he said proves the process Solomon has required doesn't work. The case involved a lawful permanent resident of the U.S. who was ineligible to vote but did so in 2018 after she said a clerk at the Ohio Bureau of Motor Vehicles mistakenly led her to believe she was allowed to do so. The woman was found not guilty by reason of entrapment.

“Under this order, the Bureau of Motor Vehicles would be required to offer a voter registration form to a person who is applying for a driver’s license, even if that person can’t verify that they’re a citizen,” LaRose said in a statement. “We strongly disagree with that decision, and I’ve asked our legal team to file an immediate appeal.”

Solomon's decision aligned with court decisions elsewhere.

In May, in the first major legal test of Trump's citizenship-related election demands, a federal judge in New Hampshire ruled that the state must make voter registration easier by letting applicants attest to their U.S. citizenship if they don’t have the documents to prove it.

When New Hampshire's law took effect for the first time, for local elections in 2025, some election clerks said they knew of would-be voters who couldn't produce the necessary documents and were turned away — for example, women who had changed their last names when they married.

In June, a federal judge permanently barred the Trump administration from implementing most of the president's first executive order on elections, including a requirement that people show documentary proof of citizenship when they register to vote. The ruling by U.S. District Court Judge Denise Casper in Boston effectively converted what was a preliminary injunction blocking much of the attempted overhaul into a permanent one.

A 2025 University of Maryland study estimates that 21.3 million Americans eligible to vote do not have documents or have easy access to the documents required to prove citizenship.