A federal judge has temporarily blocked the enforcement of an Ohio requirement that voters provide proof of citizenship when registering at a motor vehicle bureau. The rule, which took effect this year, was suspended by U.S. District Court Judge Solomon Oliver Jr. in Cleveland.
Oliver ruled that the requirement likely conflicts with the National Voter Registration Act (NVRA), which he stated takes precedence. The injunction halts the practice ahead of the October 5 registration deadline for the upcoming midterm elections. Ohio Secretary of State Frank LaRose, a Republican, indicated he would immediately appeal the decision.
The lawsuit was brought on behalf of the Ohio Alliance of Retired Americans and the progressive group Red Wine & Blue by the Elias Law Group. According to the ruling, Ohio's requirement "is more than the signed attestation to U.S. citizenship that Ohio’s other voter registration methods accept." Oliver wrote that this provision "likely conflicts with the NVRA, because it is more than ‘the minimum amount of information necessary.’"
He also found that Ohio's "motor voter" registration process has illegally limited the option to register to vote to those who successfully obtain a driver's license, rather than offering it to all applicants as federal law mandates. Ben Stafford, a partner at Elias Law, stated that the regulation is "exactly the type of government-imposed barrier that the NVRA exists to prevent."
The judge's order prevents Ohio from demanding proof of citizenship from driver's license applicants before offering them the chance to register to vote. However, it does not apply to applicants who indicate they are not U.S. citizens.
LaRose criticized the ruling, citing a case in Franklin County where a lawful permanent resident, ineligible to vote, cast a ballot in 2018 after being mistakenly told by a Bureau of Motor Vehicles clerk that she was permitted 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."
Ohio is among several states that have implemented proof-of-citizenship laws for this year's midterm elections. South Dakota, Utah, and Wyoming also enacted similar requirements, while Arizona already had a law in place for state and local elections. In South Dakota, the League of Women Voters and a voter filed a lawsuit Tuesday challenging that state's new proof-of-citizenship requirement.
Similar legal challenges have occurred in other states. In May, a federal judge in New Hampshire ruled that the state must simplify voter registration by allowing applicants to attest to their citizenship if they lack documentary proof. In June, a federal judge in Boston permanently barred the Trump administration from implementing key parts of an executive order on elections, including a requirement for documentary proof of citizenship to register to vote.
A 2025 University of Maryland study estimates that 21.3 million eligible American voters may not have easy access to the documents required to prove citizenship.