COLUMBUS, OHIO — U.S. District Court Judge Solomon Oliver Jr. issued a temporary injunction blocking enforcement of Ohio's proof-of-citizenship requirement for voter registration at motor vehicle bureaus. The injunction suspends the documentation requirement ahead of the October 5 voter registration deadline for the fall midterm elections.

Judge Solomon Oliver Jr. ruled that the Ohio requirement likely conflicts with the National Voter Registration Act because it requires more information than the minimum necessary to determine citizenship eligibility. He found that Ohio's motor voter registration process illegally limited voter registration opportunities to those who successfully obtained a driver's license, rather than offering it to everyone who submitted an application.

The lawsuit was brought on behalf of the Ohio Alliance of Retired Americans and Red Wine & Blue by the Elias Law Group. Ohio added the proof-of-citizenship requirement to its motor voter law last year.

In his ruling, Judge Oliver wrote: "Election officials do not need documentary proof of citizenship to assess a voter registration applicant’s citizenship because signed attestation of citizenship is enough."

Ohio Secretary of State Frank LaRose stated he would immediately appeal the ruling. He expressed concern that the court order would compel state agencies to process registrations without verifying legal status.

"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.

LaRose cited a 2018 Franklin County case involving a lawful permanent resident who voted after being mistakenly told by a Bureau of Motor Vehicles clerk that she was allowed to do so. The woman in the case was found not guilty by reason of entrapment.

What's New

Judge Solomon Oliver Jr. wrote in his ruling that election officials do not need documentary proof of citizenship to assess a voter registration applicant’s citizenship because signed attestation of citizenship is enough. He also wrote that interpreting the National Voter Registration Act otherwise would allow states to make registering to vote at the BMV more onerous and could result in fewer voter registrations because the opportunity to apply was not proactively offered to otherwise eligible citizens. The Bureau of Motor Vehicles is the vehicle registration and vehicle licensing agency of the U.S. state of Ohio.

Why It Matters

A 2025 University of Maryland study estimates that 21.3 million Americans eligible to vote do not have documents or easy access to documents required to prove citizenship. The injunction ensures these individuals are not barred from registering through the state's motor vehicle agencies before the upcoming election cycle.

This ruling aligns with recent judicial decisions in other jurisdictions regarding voter documentation. In May, a federal judge in New Hampshire ruled that the state must let applicants attest to U.S. citizenship for voter registration if they lack documentary proof. In June, U.S. District Court Judge Denise Casper in Boston permanently barred the Trump administration from implementing most of the president’s first executive order on elections, including a documentary proof-of-citizenship requirement for voter registration.