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Debate over the prevalence of noncitizens voting

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This article covers noncitizen voting in the United States. It includes background information about the issue, language from federal law and state constitutions, details about the municipalities that allow noncitizen voting, and a list of states where it is prohibited.

According to the Pew Research Center, there were over 25 million people living in the U.S. in 2020 who were not U.S. citizens. This included approximately 12 million permanent residents living in the U.S. with legal permission, as well as 2 million temporary residents visiting the U.S. for a period of time as students, tourists, foreign workers, foreign officials, etc. Pew's figure also includes approximately 11 million immigrants living in the U.S. illegally.[1][2]

In 1996, the U.S. Congress passed a law prohibiting noncitizens from voting in federal elections, including elections for the U.S. House, U.S. Senate, and presidential elections. This law does not apply to elections for state and local offices.[3] Click here to learn more about recent legal challenges involving noncitizen voting.

The prevalence of noncitizen voting is a subject of debate, as are proposed policy responses.

This article examines research cited by those who argue that noncitizen voting is or is not prevalent enough to threaten the integrity of U.S. elections. It also summarizes debates about policies intended to address noncitizen voting.


Overview

Federal action on noncitizen voting

The National Voter Registration Act (NVRA), passed in 1993, outlines requirements for federal voter registration, including a requirement that voters swear under penalty of perjury that they meet all eligibility requirements, citizenship among them. The law does not explicitly prohibit states from requiring proof of citizenship.[4]

In 1996, the U.S. Congress passed a law prohibiting noncitizens from voting in federal elections, including elections for the U.S. House, U.S. Senate, and presidential elections. This law does not apply to elections for state and local offices.[3] Click here to learn more about recent legal challenges involving noncitizen voting.

In 2013, the U.S. Supreme Court ruled against an Arizona law requiring that proof of citizenship be submitted alongside a voter registration application. The court found that the proof of citizenship requirement was preempted by the NVRA's requirement that voters swear they are eligible.[5] Arizona has since adopted a bifurcated voter registration system allowing voters to register for federal elections only without providing proof of citizenship. Voters who wish to participate in state and local elections may provide proof of citizenship to their county recorder's office to gain eligibility.[6]

A report published in 2016 by the Connecticut Office of Legislative Research identified four states which had introduced proof of citizenship requirements: Arizona, Alabama, Georgia, and Kansas.[4] The requirements in Alabama, Georgia, and Kansas were temporarily blocked by a September 2016 ruling of the U.S. Court of Appeals for the D.C. Circuit.[7] Kansas' proof of citizenship law was overturned by an April 2020 ruling of the Tenth Circuit Court of Appeals.[8]

State action on noncitizen voting

As of August 2025, the District of Columbia and certain municipalities in California, Maryland, and Vermont allowed noncitizens to vote in some or all local elections.

All state constitutions mention United States citizenship when discussing who can vote in that state's elections. In 33 states, constitutional language discussing citizenship says who can vote (e.g. "every citizen" or "all citizens"), but does not state that noncitizens cannot vote. In 17 states—Alabama, Arizona, Colorado, Florida, Idaho, Iowa, Kentucky, Louisiana, Missouri, North Carolina, North Dakota, Ohio, Oklahoma, South Carolina, Utah, Wisconsin, and Wyoming—their constitutions allow citizens, but not noncitizens, the right to vote.

As of August 2025, the following 17 states included language explicitly prohibiting noncitizen voting in their state constitutions.[9]

Disagreements about noncitizen voting

There is significant disagreement about the prevalence of noncitizen voting in the United States.

  • The Federation for American Immigration Reform (FAIR), which says it is a nonpartisan, public interest organization "seeking out solutions that help reduce the negative impact of uncontrolled immigration," concluded in a 2020 report, "There is enough evidence of noncitizen voting to indicate that it is an ongoing problem that may have a significant effect on American electoral politics. Due to the low risk of penalty, and the lack of effective controls, alien voting is easy."[10][11]
  • The Brennan Center for Justice, which describes itself as a nonpartisan law and policy institute, concluded in a 2017 analysis, "It is not surprising that noncitizen voting is rare. In addition to massive fines and time in prison, a noncitizen would risk deportation or derailing their naturalization process by voting. Moreover, many undocumented individuals are reluctant to interact with government officials."[12][13]

There is also significant disagreement in the U.S. about election policies that attempt to prevent noncitizens from voting.

  • The Heritage Foundation, which is a think thank that says its mission is to "promote public policies based on the principles of free enterprise, limited government, individual freedom, traditional American values, and a strong national defense," argues that verifying the citizenship status of registered voters and requiring voter identification would protect elections from noncitizen voting. In addition, Heritage argues that automatic voter registration prevents government databases from being able to generate accurate voter rolls.[14][15]
  • The American Civil Liberties Union (ACLU), which says it is a nonpartisan, nonprofit human rights organization that strives "to defend and preserve the individual rights and liberties guaranteed to every person in this country by the Constitution," argues that policies like requiring voter identification and verifying the citizenship status of registered voters actually prevent eligible citizens from voting. In addition, the Brennan Center argues that automatic voter registration is an effective way to prevent noncitizen voting.[16][17]

Support for the idea that noncitizen voting threatens election integrity

This section cites legislation and research by groups arguing that noncitizen voting is prevalent enough to threaten the security of elections in the United States.

The SAVE Act (2024)

Sen. Mike Lee (R-UT) and Rep. Chip Roy (R-TX), introduced the Safeguard American Voter Eligibility (SAVE) Act, which they say "seeks to ensure that only U.S. citizens participate in federal elections by requiring proof of citizenship for voter registration."[18]

“ Illegal immigrants and non-citizens across the nation are being improperly registered to vote, allowing them to cast illegitimate ballots in federal elections ... At a time when trust in voting is more important than ever, we must stop foreign election interference and pass the SAVE Act. Voting is both a sacred right and responsibility of American citizenship, and allowing the people of other nations access to our elections is a grave blow to our security and self-governance. I’m proud to stand with Chip Roy to save our democratic process and representative government.[18][19] ”
—Sen. Mike Lee
“ Secure elections are a key cornerstone for any representative government; without them, we won't have a country ... Radical progressive Democrats know this and are using open border policies while also attacking election integrity laws to fundamentally remake America. That's why I am proud to introduce the SAVE Act with Speaker Johnson and my Republican colleagues, along with the invaluable support of citizens and organizations that recognize we must end the practice of non-citizens voting in our elections.[18][19] ”
—Rep. Chip Roy

Heritage Foundation Voter Fraud Database (2024)

The Heritage Foundation's Voter Fraud Database contained entries for at least 80 noncitizens found to have voted in U.S. elections as of May 2024.[20]

According to Heritage, its database contains a sampling of "election fraud cases from across the country, broken down by state, where individuals were either convicted of vote fraud, or where a judge overturned the results of an election."[21]

Public Interest Legal Foundation and the Virginia Voter Alliance report (2017)

In 2017, a report on noncitizen voting in Virginia was released by the following two organizations:

The Public Interest Legal Foundation (PILF), which says it exists to "assist states and others to aid the cause of election integrity and fight against lawlessness in American elections," and the Virginia Voter Alliance (VVA), which says it promotes "ideas that actively protect the rights of legitimate voters."[22][23]

The report's authors concluded the following:

“
  • Virginia election officials quietly removed 5,556 voters for non-citizenship between 2011 and May 2017;
  • 1,852 of those removed as noncitizens cast ballots;
  • A total of 7,474 illegal ballots were cast from the pool of removed noncitizens;
  • Some records of illegal voting date back to the 1980s before their respective removals;
  • Virginia election officials routinely fail to alert law enforcement about these illegal votes or registrations.[19]
 ”

According to the report, data on previously registered noncitizens came from the Virginia Department of Elections. PILF "worked with a third party with access to voter history to determine which of the aliens who registered to vote, actually voted."[24]

Old Dominion University and George Mason University study (2014)

The FAIR report on noncitizen voting referenced above cites a 2014 study by researchers from Old Dominion University and George Mason University as part of its argument for the prevalence of noncitizen voting. The study is summarized below.

The researchers estimated that 6.4 percent of noncitizens voted in the 2008 presidential election and that 2.2 percent voted in the 2010 midterm election. Of the 2008 estimate, the authors wrote, "Since the adult non-citizen population of the United States was roughly 19.4 million (CPS 2011), the number of non-citizen voters (including both uncertainty based on normally distributed sampling error, and the various combinations of verified and reported voting) could range from just over 38,000 at the very minimum to nearly 2.8 million at the maximum."[25]

In their conclusion, the authors wrote the following:

“

These results speak to both sides of the debate concerning non-citizen enfranchisement. They support the claims made by some anti-immigration organizations that non-citizens participate in U.S. elections. In addition, the analysis suggests that non-citizens’ votes have changed significant election outcomes including the assignment of North Carolina’s 2008 electoral votes, and the pivotal Minnesota Senate victory of Democrat Al Franken in 2008.

However, our results also support the arguments made by voting and immigrant rights organizations that the portion of non-citizen immigrants who participate in U.S. elections is quite small. Indeed, given the extraordinary efforts made by the Obama and McCain campaigns to mobilize voters in 2008, the relatively small portion of non-citizens who voted in 2008 likely exceeded the portion of non-citizens voting in other recent U.S. elections.[25][19]

”

Data for the study came from the 2008 and 2010 Cooperative Congressional Election Studies. In the 2008 survey, 339 respondents identified as noncitizens, and 489 identified as noncitizens in the 2010 survey.[26][25]

Opposition to the idea that non-citizen voting threatens election integrity

This section cites legislation and research by groups arguing that noncitizen voting is not prevalent enough to threaten the security of elections in the United States.

D.C. noncitizen voting law (2024)

In a 2024 article in The DCist, Hector Alejandro Arcate discussed a law in the District of Columbia expanding voting rights in certain elections to noncitizens. The law allows noncitizens to vote in elections for mayor, council, attorney general, state board of education, and more:[27]

“ [As of Feb. 1, 2024], about 23 people total have registered to vote in D.C. as non-citizens, according to a spokesperson for the DCBOE ... [I]t’s not quite the 50,000 or so potential voters that advocates previously estimated, but is a hard-won number after years of failed bills and recent efforts in Congress to overturn the bill once it finally passed in D.C. Council. ...


Ward 1 Council member Brianne K. Nadeau, who introduced the bill and some of its previous iterations, says it was long overdue for longtime residents. She says many pay taxes and raise their children in local schools, and should have a say in the next election.

'I think if it’s a good idea the first time, it’s still going to be a good idea every subsequent time,' says Nadeau. 'It really hits home because in the District of Columbia, we already don’t have a voice in our federal government. And so allowing for that participation locally can only strengthen our community and engagement and the outcomes of our elections.'[19]

”

The Cato Institute article (2024)

In a 2024 article for the Cato Institute, which says it is a "public policy research organization—or think tank—that creates a presence for and promotes libertarian ideas in policy debates," Senior Fellow Walter Olson wrote about his discussions with public sector statistics expert Brian Quinn:[28]

“

A common way of monitoring the integrity of elections is to apply statistical tests, looking for instances in which electoral results differ inexplicably from otherwise logical patterns. In this case, given common knowledge that certain localities have a high share of noncitizen residents, we can ask whether the number of votes cast relates reasonably to the known number of legally eligible voting‐​age citizens, applying plausible turnout expectations, or whether it comes in unaccountably higher than that, which might suggest seepage from the pool of ineligible persons. Tests of this sort “show nothing like widespread noncitizen voting. ...

California is an example: It is a state where certain counties are universally assumed to be home to far more than their share of immigrants, including urban Los Angeles County as well as counties in the agricultural Central and Imperial valleys. 'If a material number of those noncitizens were voting, total voters as a share of known eligible voters would be high.' It’s actually quite low as a share of legally eligible voters, probably due largely to low median age.

The 22nd California congressional district, for example, represented by Republican David Valadao, consists in substantial part of agricultural areas in the Central Valley with a very high share of noncitizens. It cast only about 100,000 votes in the closely contested 2022 midterms, an election in which many other districts around the state recorded 200,000 or even 300,000 votes. The same pattern, Quinn says, in which participation rates fail to come in suspiciously high when compared with the pool of lawful voters, “is consistent in every state. You can see it in Texas, Arizona, Florida, New York, and so forth.[29][19]

”

The Brennan Center for Justice article (2024)

In a 2024 article for the Brennan Center, Director of Voting Rights Sean Morales-Doyle argued that instances of noncitizen voting are rare, writing:

“

Every legitimate study ever done on the question shows that voting by noncitizens in state and federal elections is vanishingly rare. That includes the Brennan Center’s own study of 42 jurisdictions in the 2016 general election. We found that election officials in those places, who oversaw the tabulation of 23.5 million votes, referred only an estimated 30 incidents of suspected noncitizen voting for further investigation or prosecution. In other words, even suspected — not proven — noncitizen votes accounted for just 0.0001 percent of the votes cast. But you don’t have to take our word for it: the Cato Institute will also tell you, 'Noncitizens don’t illegally vote in detectable numbers.'"[30][19]

”

The 2016 Brennan Center study that Morales-Doyle references was based on information provided by 44 local election administrators. The study stated the following:

“
  • In the jurisdictions we studied, very few noncitizens voted in the 2016 election. Across 42 jurisdictions, election officials who oversaw the tabulation of 23.5 million votes in the 2016 general election referred only an estimated 30 incidents of suspected noncitizen voting for further investigation or prosecution. In other words, improper noncitizen votes accounted for 0.0001 percent of the 2016 votes in those jurisdictions.
  • Forty of the jurisdictions — all but two of the 42 we studied — reported no known incidents of noncitizen voting in 2016. All of the officials we spoke with said that the incidence of noncitizen voting in prior years was not significantly greater than in 2016.
  • In the ten counties with the largest populations of noncitizens in 2016, only one reported any instances of noncitizen voting, consisting of fewer than 10 votes, and New York City, home to two of the counties, declined to provide any information.
  • In California, Virginia and New Hampshire — the states where [President Donald] Trump claimed the problem of noncitizen voting was especially acute — no official we spoke with identified an incident of noncitizen voting in 2016.[31][19]
 ”

Movement Advancement Project report (2022)

A 2022 report for the Movement Advancement Project, which is an advocacy organization that says its mission is to "provide independent and rigorous research, insight, and communications that help speed equality and opportunity for all people," argued that voter ID laws meant to prevent noncitizen voting hurt certain communities of eligible voters:[32]

“ Despite the importance of IDs in the United States, there are many key systems-level failures that often make it difficult for many people, across all walks of life, to get and maintain an accurate ID. ... [A]n estimated 12% of all adults, or nearly 30 million people, lack a valid driver’s license, with even higher rates among different communities.

Complicated documentation requirements, financial costs that can quickly snowball, long wait times at or limited availability of ID-issuing locations, a complex patchwork of policies that change from one state to the next, and discrimination and prejudice all interact to create an intricate web of roadblocks to getting accurate ID. These challenges apply both to getting an ID in the first place and then ... also keeping that ID up to date over a lifetime of different events and experiences that might necessitate changes.
Taken together, these system failures mean that getting and maintaining an accurate ID can be at best inconvenient, and at worst nearly impossible. And, as discussed throughout this report, many communities— such as communities of color, transgender and nonbinary people, and more—are even more likely to lack an ID.[19]

”

Debates about policy responses

Election administration encompasses a state's voting policies and methods of enforcing them. These include voter identification requirements, citizenship verification for voter registration, automatic voter registration, and more. Each state's voting policies dictate who can vote and under what conditions. These policies are often subjects of debate.

The lists below include quotations providing more details about election administration policy debates related to noncitizen voting.

Voter identification requirements

See also: Voter identification laws by state

Thirty-five states require voters to present identification in order to vote at the polls on Election Day. Of these states, 23 require voters to present identification containing a photograph, and 12 accept other forms of identification. The remaining 15 states do not require voters to present identification in order to vote at the polls on Election Day.

Valid forms of identification differ by state. In certain states that require voters to provide identification, there may be exceptions that allow some voters to cast a ballot without providing an ID. To see more about these exceptions, see details by state. Commonly accepted forms of ID include driver's licenses, state-issued identification cards, and military identification cards.

Supporters of requiring voter ID argue it would prevent noncitizens from voting.

  • In a 2020 report, the Federation for American Immigration Reform (FAIR) argued that voter identification requirements were needed for federal, state, and local elections to address non-citizen voting. Because most states use driver's licenses as identifications for voter registration, FAIR stated that driver's licenses need to be in true compliance with the Real ID Act of 2005.[33]
  • In an article for the Heritage Foundation, senior legal fellow Hans von Spakovsky wrote, "Since the vast majority of states (and the federal government) will not issue an official identification to an illegal alien, requiring state or federally issued photo IDs can also prevent noncitizens, particularly illegal aliens, from voting in elections. ... States that issue driver’s licenses to noncitizens who are in the United States legally should ensure that such licenses note on their face that the holder is not a U.S. citizen."[34]
  • J. Christian Adams, president of the Public Interest Legal Foundation, said, "Two-factor authentication is a part of our daily lives. Think of the last time a website sent you a text message to prove you are you. Now that our voter registration systems are being targeted by bad actors like Russia, we need ID requirements more than ever to access securely our own records for voting or even address changes."[35]

Opponents of requiring voter ID argue it may prevent eligible voters from voting.

  • The Brennan Center for Justice argued that "strict voter ID laws place barriers in front of the ballot box for many eligible Americans."[36]
  • The ACLU argued that voter identification requirements can be discriminatory. "Many Americans do not have one of the forms of identification states acceptable for voting. These voters are disproportionately low-income, racial and ethnic minorities, the elderly, and people with disabilities. Such voters more frequently have difficulty obtaining ID, because they cannot afford or cannot obtain the underlying documents that are a prerequisite to obtaining government-issued photo ID card."[37]
  • Danielle Root, the associate director of the Center for American Progress' Voting Rights and Access to Justice program, said, "Besides disproportionately harming historically underrepresented groups, voter IDs are redundant and have repeatedly proven unnecessary. For instance, voters are already required to attest to their identity and eligibility when they vote. Moreover, death by lightning strike is more common than occurrences of in-person voter impersonation, the only kind of fraud voter IDs purport to prevent."[35]

Citizenship verification

FAIR and the Heritage Foundation both argue that steps should be taken to verify the citizenship status of registered voters:

  • In an article for the Heritage Foundation, Spakovsky wrote, "All states should require anyone who registers to vote to provide proof of U.S. citizenship. This requirement should be identical to the federal requirement of proof for employment." Spakovsky wrote that E-Verify, which is a federal database on persons' eligibility to work in the U.S., "should be made available to election officials and administrators of the statewide registration databases..."
  • According to FAIR, voter registration rolls should be cross-checked with government records, such as the Department of Homeland Security's Systematic Alien Verification for Entitlements (SAVE).[33][38][39]

The Brennan Center and the American Immigration Council both argued that requiring proof of citizenship for voter registration would prevent eligible citizens from voting.

  • The ACLU argued that the documents needed to prove citizenship aren't common items. "Most people don’t carry the required documents on hand — like a passport, or a birth certificate," wrote Leila Rafei, an ACLU content strategist.[40]
  • Ian Vandewalker, senior counsel for the Brennan Center for Justice, wrote that proof-of-citizenship documents "would block significant numbers of citizens from registering."[41]
  • The American Immigration Council wrote, "According to news reports, DHS officials had previously declined to allow the use of SAVE for the purpose of verifying the citizenship or immigration status of registered voters because the information is 'incomplete and does not provide comprehensive data on all eligible voters.'"[42]

Automatic voter registration

See also: Automatic voter registration

Under an automatic voter registration system, eligible voters are automatically registered to vote whenever they interact with certain government agencies, such as departments of motor vehicles. Eligible voters are registered by default, although they may request not to be registered.[43][44]

As of June 2024, 24 states and the District of Columbia had enacted automatic voter registration policies. See the map below.[43][45]

Supporters of automatic voter registration argue it would prevent noncitizens from voting.

  • A 2017 report for the Brennan Center for Justice titled "Noncitizen Voting: The Missing Millions" stated that while allegations of non-citizen voting are unfounded, voter roll errors do occur. "These errors include the registration of ineligible people, and the non-registration of eligible people. ... Common-sense steps could safeguard integrity while assuring that all eligible citizens can vote. Automatic voter registration, for example, would clean up voter rolls."[46]
  • A 2015 Brennan Center report titled "Automatic and Permanent Voter Registration: How It Works," stated, "The most appropriate agencies for automatic registration are those that already collect reliable citizenship information. In those instances, automatic registration is a simple matter of transferring only the records of citizens from an agency to an election office. The agency’s already vetted information will form the basis for voter registration records and updates. And during the sign-up process, the government will provide people with notice of voter eligibility requirements and that they are being registered to vote, along with the opportunity to decline registration for any reason, including because they are not eligible.
    To be clear, automatic registration does not require that state agencies begin collecting citizenship information if they do not already do so. As a state moves toward automatic registration, it should explore which of its agencies already require and store citizenship information and what tweaks, if any, are needed to use this already-collected information to register voters.[47]

Opponents of automatic voter registration argue it would not prevent noncitizens from voting effectively.

  • A 2018 report from the Heritage Foundation argued that government databases are ineffective at creating accurate voter rolls and that they could lead to errors. "While government records are useful for verifying voter registrations, research shows they would be ineffective in creating accurate voter rolls. One of the most glaring problems with these databases is that they cannot verify a basic eligibility requirement for voting — citizenship. Non-citizens can receive driver’s licenses in all 50 states, and illegal aliens are receiving licenses in more than a dozen states, including California. Noncitizens also pay property taxes. Automatic voter registration would register all such ineligible individuals.
    Moreover, individuals can be listed multiple times in different government databases that would be a source for automatic registration. For example, one person may pay taxes in multiple counties and multiple states, raising the possibility that he could vote multiple times, in multiple jurisdictions. Also, voter registration requires a signature to verify petitions, ballot initiatives, and absentee ballots. Many government databases don’t contain signatures and thus would be useless for verifying signatures."[48]

Related topics

This and other pages on Ballotpedia cover types of election and voter fraud for which there are documented cases and around which there is debate concerning the frequency of instances and proposed responses.

See also

Ballotpedia:Index of Terms

Footnotes

  1. ↑ Note that Pew's count of immigrants living in the U.S. illegally included individuals with temporary protection from deportation, like under the Deferred Action for Childhood Arrivals (DACA) program.
  2. ↑ Pew Research Center, "Key findings about U.S. immigrants," August 20, 2020
  3. ↑ 3.0 3.1 Cornell Law School, "18 U.S. Code § 611 - Voting by aliens," accessed February 15, 2023
  4. ↑ 4.0 4.1 Connecticut General Assembly, "Documentary Proof of Citizenship for Voter Registration," accessed May 1, 2020
  5. ↑ U.S. News and World Report, "Supreme Court Rules Against Arizona Proof of Citizenship Law," June 17, 2013
  6. ↑ Arizona Secretary of State, "Proof of Citizenship Requirements," accessed May 1, 2020
  7. ↑ National Public Radio, "Court Blocks Proof-Of-Citizenship Requirement For Voters In 3 States," September 10, 2016
  8. ↑ ABC News, "Court: Kansas can't require voters to show citizenship proof," April 29, 2020
  9. ↑ Berkeley Public Policy Journal, "Spring 2019 Journal: Noncitizen Voting Rights in the United States," March 4, 2019
  10. ↑ Federation for American Immigration Reform, "About Us," accessed May 3, 2024
  11. ↑ FAIR, "Noncitizens, Voting Violations and U.S. Elections," July 2020
  12. ↑ Brennan Center for Justice, "About Us," April 18, 2018
  13. ↑ The Brennan Center for Justice, "Analysis: Noncitizen Voting is Vanishingly Rare," January 25, 2017
  14. ↑ The Heritage Foundation, "Mandatory Voter Registration: How Universal Registration Threatens Electoral Integrity," March 27, 2013
  15. ↑ The Heritage Foundation, "About Heritage," accessed May 2, 2024
  16. ↑ ACLU, "ACLU History," accessed May 2, 2024
  17. ↑ Brennan Center for Justice, "Automatic Voter Registration," accessed May 2, 2024
  18. ↑ 18.0 18.1 18.2 Mike Lee, U.S. Senator for Utah, "Lee and Roy Partner on Legislation to Secure Federal Elections," May 8, 2024
  19. ↑ 19.0 19.1 19.2 19.3 19.4 19.5 19.6 19.7 19.8 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
  20. ↑ Ballotpedia searched within the "Ineligible voting" category of the database for the term "citizen" and read summaries of each return to find relevant cases.
  21. ↑ The Heritage Foundation, "Election Fraud Cases," accessed May 3, 2024
  22. ↑ Public Interest Legal Foundation, "About Us," accessed April 23, 2020
  23. ↑ Virginia Voter Alliance, "About," accessed April 23, 2020
  24. ↑ Public Interest Legal Foundation, "Alien Invasion II: The Sequel to the Discovery and Cover-up of Non-citizen Registration and Voting in Virginia," May 2017
  25. ↑ 25.0 25.1 25.2 Old Dominion University, "Do Non-Citizens Vote in U.S. Elections?" 2014
  26. ↑ According to the researchers, "The data used for this paper is from the 2008 and 2010 Cooperative Congressional Election Studies, based on the files released by Stephen Ansolabehere (2010, 2011). The 2008 and 2010 Cooperative Congressional Election Studies (CCES) were conducted by YouGov/Polimetrix of Palo Alto, CA as an internet-based survey using a sample selected to mirror the demographic characteristics of the U.S. population."
  27. ↑ The DCist, "About Cato," accessed May 3, 2024
  28. ↑ The Cato Institute, "About Cato," accessed May 3, 2024
  29. ↑ The Cato Institute, "The Right’s Bogus Claims about Noncitizen Voting Fraud," April 11, 2024
  30. ↑ The Brennan Center for Justice, "Noncitizens Are Not Voting in Federal or State Elections — Here’s Why," April 12, 2024
  31. ↑ The Brennan Center for Justice, "Noncitizen Voting: The Missing Millions," May 5, 2017
  32. ↑ Movement Advancement Project, "The ID Divide: How Barriers to ID Impact Different Communities and Affect Us All," November 2022
  33. ↑ 33.0 33.1 Cite error: Invalid <ref> tag; no text was provided for refs named fairreport
  34. ↑ The Heritage Foundation, "Voter Photo Identification: Protecting the Security of Elections," July 13, 2011
  35. ↑ 35.0 35.1 Kirksville Daily Express, "Pro-Con: Do we need voter ID laws?" January 25, 2020
  36. ↑ Brennan Center for Justice, "The Truth About Voter Fraud," November 9, 2007
  37. ↑ ACLU, "Oppose ID Legislation," accessed April 28, 2020
  38. ↑ The Heritage Foundation, "The Threat of Non-Citizen Voting," July 10, 2008
  39. ↑ The Heritage Foundation, "Do Illegal Votes Decide Elections?" December 15, 2016
  40. ↑ ACLU, "Block the Vote: Voter Suppression in 2020," February 3, 2020
  41. ↑ The Brennan Center for Justice, "The Effects of Requiring Documentary Proof of Citizenship," July 19, 2017
  42. ↑ American Immigration Council, "Using the Systematic Alien Verification for Entitlements (SAVE) Program for Voter Eligibility Verification," August 2, 2012
  43. ↑ 43.0 43.1 National Conference of State Legislatures, "Automatic Voter Registration," February 12, 2024
  44. ↑ Brennan Center for Justice, "Automatic Voter Registration," October 26, 2023
  45. ↑ Cite error: Invalid <ref> tag; no text was provided for refs named hf3
  46. ↑ Brennan Center for Justice, "Noncitizen Voting: The Missing Millions," 2017
  47. ↑ [brennancenter.org/sites/default/files/publications/Automatic_Permanent_Voter_Registration_How_It_Works.pdf The Brennan Center for Justice, "Automatic and Permanent Voter Registration: How It Works," 2015]
  48. ↑ Heritage Foundation, "Is It Too Much to Expect Voters to Register? The Left Thinks So," October 26, 2018
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