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Massachusetts Question 3, Changes to Alcohol Retail Licensing Initiative (2022)

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Massachusetts Question 3
Flag of Massachusetts.png
Election date
November 8, 2022
Topic
Alcohol
Status
Defeatedd Defeated
Type
State statute
Origin
Citizens

Massachusetts Question 3, the Changes to Alcohol Retail Licensing Initiative, was on the ballot in Massachusetts as an indirect initiated state statute on November 8, 2022.[1] The ballot measure was defeated.

A "yes" vote supported this ballot initiative to:

  • incrementally increase the combined number of retail beer and wine licenses and all alcoholic beverage licenses (including liquor) an establishment could own from no more than nine in 2022 to no more than 18 by 2031;
  • limit the maximum number of licenses for the sale of all alcoholic beverages an establishment could own to seven; 
  • prohibit in-store automated or self-checkout sales of alcohol;
  • change the formula used to calculate fines by using gross profits on all retail sales rather than the gross profits on the sale of alcohol; and
  • add out-of-state driver's licenses to the list of approved identification under the State Liquor Control Act.

A "no" vote opposed this ballot initiative that would make changes to alcohol retail licensing, fining, and operations.


Election results

Massachusetts Question 3

Result Votes Percentage
Yes 1,069,921 44.90%

Defeated No

1,312,906 55.10%
Results are officially certified.
Source


Overview

What would Question 3 have done?

See also: Text of measure

Question 3 would have incrementally increased the statewide limit on the combined number of retail alcohol licenses an establishment could have, which includes licenses for all alcoholic beverages (including liquor) and for wine, malt, and beer. The measure proposed the following limit increases:[1]

  • from nine licenses to 12 on January 1, 2023,
  • from 12 licenses to 15 on January 1, 2027, and
  • from 15 licenses to 18 on January 1, 2031.

The measure would have limited the maximum number of licenses for the sale of all alcoholic beverages an establishment could have to seven beginning in 2023 unless the retailer already holds more than seven on December 31, 2022.[1]

Question 3 would have also prohibited in-store automated and self-checkout sales of alcohol. It would have also changed the formula used to calculate fines for selling to underage consumers by using gross profits on all retail sales instead of gross profits on alcoholic beverage sales. At the time of the election, the formula to calculate fines equals 50% of the daily gross profits on the sale of alcohol multiplied by the number of license suspension days. Fines are levied in lieu of suspension of a license.[1][2]

Question 3 would have also changed the laws governing identification cards for alcohol purchases to include a valid motor vehicle license issued by another state.[1]

Who supported and opposed Question 3?

See also: Supports and Opposition

21st Century Alcohol Retail Reform Committee led the campaign in support of Question 3. The committee has reported $1.1 million in contributions with $701,049 of the total from the Massachusetts Package Stores Association. The association wrote on its website, "Why vote yes on Question #3? Balance will be restored by decreasing the number of full liquor licenses allowed by an individual or corporation from nine (9) to seven (7), while progressively increasing the number of beer and wine licenses from nine (9) to eighteen (18), minus any full liquor licenses owned by the corporation or individual. To improve public safety, self-checkout of alcohol beverages will be prohibited and a fine for selling to a minor will be based on gross sales, not just for alcohol beverages. The initiative petition also helps the entire alcohol beverages industry by allowing for valid out of state IDs to be relied upon. Massachusetts is the only state in the U.S. that does not permit a retailer to reasonably rely on valid out-of-state IDs."[3]

Food Stores for Consumer Choice was registered in opposition to Question 3. The committee had reported $12.50 in contributions. Massachusetts Fine Wines & Spirits, LLC (Total Wine) reported $2.6 million in independent expenditures to oppose Question 3. Ryan Kearney, general counsel for the Retailers Association of Massachusetts, said, "We consider this to be overreach and a blatant attempt to stifle competition from businesses that seek to offer a wide array of products." Brian Houghton, senior vice president of the Massachusetts Food Association, said, "It is not fair or rational to limit multi-store grocers to a limited number of full licenses they can hold statewide simply because they sell food."[4]

Text of measure

Ballot question

The ballot question was as follows:[5]

Do you approve of a law summarized below, on which no vote was taken by the Senate or the House of Representatives on or before May 3, 2022?[6]

Ballot summary

The final ballot summary for Question 3 was as follows.[7]

This proposed law would increase the statewide limits on the combined number of licenses for the sale of alcoholic beverages for off-premises consumption (including licenses for 'all alcoholic beverages' and for 'wines and malt beverages') that any one retailer could own or control: from 9 to 12 licenses in 2023; to 15 licenses in 2027; and to 18 licenses in 2031.

Beginning in 2023, the proposed law would set a maximum number of 'all alcoholic beverages' licenses that any one retailer could own or control at 7 licenses unless a retailer currently holds more than 7 such licenses.

The proposed law would require retailers to conduct the sale of alcoholic beverages for off-premises consumption through face-to-face transactions and would prohibit automated or self-checkout sales of alcoholic beverages by such retailers.

The proposed law would alter the calculation of the fine that the Alcoholic Beverages Control Commission may accept in lieu of suspending any license issued under the State Liquor Control Act. The proposed law would modify the formula for calculating such fee from being based on the gross profits on the sale of alcoholic beverages to being based on the gross profits on all retail sales.

The proposed law would also add out-of-state motor vehicle licenses to the list of the forms of identification that any holder of a license issued under the State Liquor Control Act, or their agent or employee, may choose to reasonably rely on for proof of a person’s identity and age.[6]

Full text

The full text of the measure is below:

Readability score

See also: Ballot measure readability scores, 2022

Using the Flesch-Kincaid Grade Level (FKGL) and Flesch Reading Ease (FRE) formulas, Ballotpedia scored the readability of the ballot title and summary for this measure. Readability scores are designed to indicate the reading difficulty of text. The Flesch-Kincaid formulas account for the number of words, syllables, and sentences in a text; they do not account for the difficulty of the ideas in the text. The secretary of state wrote the ballot language for this measure.

The FKGL for the ballot title is grade level 11, and the FRE is 60. The word count for the ballot title is 26.

The FKGL for the ballot summary is grade level 19, and the FRE is 23. The word count for the ballot summary is 243.


Support

Yes on 3 MA 2022.png

21st Century Alcohol Retail Reform Committee led the campaign in support of Question 3.[8]

Supporters

Corporations

  • Sav-Mor Spirits

Unions

  • Massachusetts Package Stores Association

Arguments

  • Massachusetts Package Stores Association: "Why vote yes on Question #3? Balance will be restored by decreasing the number of full liquor licenses allowed by an individual or corporation from nine (9) to seven (7), while progressively increasing the number of beer and wine licenses from nine (9) to eighteen (18), minus any full liquor licenses owned by the corporation or individual. To improve public safety, self-checkout of alcohol beverages will be prohibited and a fine for selling to a minor will be based on gross sales, not just for alcohol beverages. The initiative petition also helps the entire alcohol beverages industry by allowing for valid out of state IDs to be relied upon. Massachusetts is the only state in the U.S. that does not permit a retailer to reasonably rely on valid out-of-state IDs."

Official arguments

The following is the argument in support of Question 3 found in the Official Voter Information Guide:[9]

  • Official Voter Information Guide: A YES vote fulfills consumer desire for expanded convenience in a reasonable and balanced manner that also protects against illegal sales. A YES vote expands convenience by gradually increasing the total number of alcoholic beverage licenses that any person or company can own. Package stores, convenience stores, supermarkets, superstore retailers, and others will be able to apply for additional licenses for their existing locations that do not currently sell alcohol and for new locations they open. A YES vote simultaneously enhances public safety and encourages vigilance by retailers through prohibiting self-checkout of alcohol beverages and basing the fine for selling to a minor on a store’s total sales and not just its alcohol sales. A YES vote also supports state tourism and brings Massachusetts in line with every other state in the country by allowing for valid out of state IDs to be relied upon by alcohol beverage retailers. ---Robert Mellion, 21st Century Alcohol Retail Reform Committee

Opposition

Food Stores for Consumer Choice led the campaign in opposition to Question 3.[10]

Opponents

Corporations

  • Cumberland Farms
  • Total Wine

Unions

  • Massachusetts Food Association
  • New England Convenience Store and Energy Marketers Association

Organizations

  • Retailers Association of Massachusetts

Arguments

  • Ryan Kearney, general counsel for Retailers Association of Massachusetts: "We consider this to be overreach and a blatant attempt to stifle competition from businesses that seek to offer a wide array of products."
  • Brian Houghton, senior vice president of the Massachusetts Food Association: "It is not fair or rational to limit multi-store grocers to a limited number of full licenses they can hold statewide simply because they sell food."
  • John Hurst, president of the Retailers Association of Massachusetts: "If you’re a package store, you’re going to take a fine in order to stay open. But if you’re a convenience store or food store, and all of the sudden you’re going from being fined on your alcohol sales to your food, gasoline... you can’t shut down and stop selling gasoline and food to your customers. You can’t have that exorbitant fine. You’ll just stop selling alcohol — and that was the intent."

Official arguments

The following is the argument in opposition to Question 3 found in the Official Voter Information Guide:[11]

  • Official Voter Information Guide: Our alcohol licensing laws do need serious reforms, but this ballot measure is not the answer. It offers an incomplete solution to a complex problem, doing little to promote competition or expand consumer choice. Despite some superficially popular provisions designed to entice voters, it fails to lift outdated restrictions on local decision-making, while in fact moving Massachusetts backwards in several significant ways: (1)imposing unfair penalties against retailers who sell more than just alcohol, like grocers and other food stores; (2) outlawing convenient and reliable point-of-sale technologies already in widespread use by retailers across the state; (3) decreasing the number of full liquor licenses that retailers can own. This flawed approach favors special interests in the alcohol industry, at the expense of cash-strapped consumers and their favorite local retailers. We deserve more. Vote NO on this question, and instead ask your state lawmakers to support comprehensive legislation that will actually make a difference. ---Food Stores for Consumer Choice

Campaign finance

The campaign finance information on this page reflects the most recent scheduled reports that Ballotpedia has processed, which covered through January 20, 2023.


See also: Campaign finance requirements for Massachusetts ballot measures

There was one committee registered in support of the measure: 21st Century Alcohol Retail Reform Committee. The committee reported $1.1 million in contributions. There was one committee registered in opposition to the measure: Food Stores for Consumer Choice. The committee did not report cash contributions. Massachusetts also required other organizations that spend money to support or oppose ballot measures to report amounts to the Massachusetts Office of Campaign and Political Finance. Massachusetts Fiscal Alliance reported $12,858.92 spent in opposition to Question 3. Massachusetts Fine Wines & Spirits, LLC (Total Wine) reported $2.7 million in opposition to Question 3.[8][12]

Cash Contributions In-Kind Contributions Total Contributions Cash Expenditures Total Expenditures
Support $991,300.00 $139,955.04 $1,131,255.04 $991,300.00 $1,131,255.04
Oppose $0.00 $12.50 $12.50 $0.00 $12.50
Total $991,300.00 $139,967.54 $1,131,267.54 $991,300.00 $1,131,267.54

Support

The following table includes contribution and expenditure totals for the committee in support of the ballot measure.[8]

Committees in support of Question 3
Committee Cash Contributions In-Kind Contributions Total Contributions Cash Expenditures Total Expenditures
21st Century Alcohol Retail Reform Committee $991,300.00 $139,955.04 $1,131,255.04 $991,300.00 $1,131,255.04
Total $991,300.00 $139,955.04 $1,131,255.04 $991,300.00 $1,131,255.04

Donors

The following table shows the top donor to the committee registered in support of the ballot measure.[8]

Donor Cash Contributions In-Kind Contributions Total Contributions
Massachusetts Package Stores Association $635,380.00 $65,668.80 $701,048.80
Julio's Liquors $6,000.00 $8,180.19 $14,180.19
Deerfield Spirit Shoppe $10,000.00 $0.00 $10,000.00
Liquors 44 $7,500.00 $0.00 $7,500.00
Jay's Wine & Spirits $0.00 $6,291.25 $6,291.25

Opposition

The following table includes contribution and expenditure totals for the committee in opposition to the ballot measure.[8]

Committees in support of Question 3
Committee Cash Contributions In-Kind Contributions Total Contributions Cash Expenditures Total Expenditures
Food Stores for Consumer Choice $0.00 $12.50 $12.50 $0.00 $12.50
Total $0.00 $12.50 $12.50 $0.00 $12.50

Methodology

To read Ballotpedia's methodology for covering ballot measure campaign finance information, click here.

Media editorials

See also: 2022 ballot measure media endorsements

Ballotpedia identified the following media editorial board as taking positions on Question 3.

Ballotpedia lists the positions of media editorial boards that support or oppose ballot measures. This does not include opinion pieces from individuals or groups that do not represent the official position of a newspaper or media outlet. Ballotpedia includes editorials from newspapers and outlets based on circulation and readership, political coverage within a state, and length of publication. You can share media editorial board endorsements with us at editor@ballotpedia.org.

Support

  • The Boston Globe Editorial Board: "The chain stores beckon — so cheap and convenient. But spending too much money in a big box can feel like a betrayal of the small, mom-and-pop stores that give our neighborhoods life. Striking a balance is key to building a healthy economy and healthy communities. And Question 3 on the Massachusetts ballot is a good if imperfect step toward striking that balance in one sector, at least: alcohol sales. The Globe urges a yes vote on the measure. ... Overall, though, Question 3 is a good compromise. It gives chains like Trader Joe’s and BJ’s Wholesale Club and Total Wine a chance to sell beer and wine in more locations, in a win for consumers. But it wouldn’t blow up the caps altogether. And that means neighborhood package stores will still have a fighting chance."
  • The Berkshire Eagle Editorial Board: "Ballot Question 3 asks voters to approve lifting the cap on the number of liquor licenses that a single retailer can control in Massachusetts as well as several minor adjustments to the state’s alcohol sale laws. ... Since the Legislature has unfortunately left that responsibility to the voters once again, The Eagle endorses a yes vote on Question 3."
  • The Harvard Crimson Editorial Board: "If passed, Ballot Question Three could be a win for packies over big corporations (albeit one born out of compromise!) and those in favor of a more safe and more fun nightlife involving responsible alcohol consumption. Our state can do better than second-to-Utah; our local stores deserve protection and our consumers deserve the ability to buy low-grade alcohol at more locations. For those reasons, we urge voters to vote yes on Ballot Question Three."


Opposition

You can share campaign information or arguments, along with source links for this information, at editor@ballotpedia.org.


Polls

See also: Ballotpedia's approach to covering polls and 2022 ballot measure polls
Are you aware of a poll on this ballot measure that should be included below? You can share ballot measure polls, along with source links, with us at editor@ballotpedia.org.
Massachusetts Question 3, Changes to Alcohol Retail Licensing Initiative (2022)
Poll
Dates
Sample size
Margin of error
Support
Oppose
Undecided
UMass Amherst/WCVB 10/20/22 - 10/26/22 700 RV ± 4.3% 39% 38% 23%
Question: "Question 3 - Would increase the statewide limit on the combined number of licenses for the sale of alcoholic beverages for off premises consumption that any one retailer could own or control."

Note: LV is likely voters, RV is registered voters, and EV is eligible voters.

Background

Massachusetts alcohol licensing and regulation

The Alcoholic Beverages Control Commission (ABCC) is authorized to oversee the manufacturing, importing, exporting, storing, transporting, and selling of alcoholic beverages in the state. Local Licensing Authorities (LLA) are authorized to issue retail licenses for on-premises consumption (restaurants, hotels, clubs, and general-on-premises) and off-premises consumption (package stores, grocery stores, and convenience stores). The licensing process requires (i) the LLA to grant a license; (ii) the ABCC to approve the license; and (iii) the LLA to issue the license upon receipt of the licensing fee. State law requires a license quota system that limits the number of licenses the LLA can issue in an area based on population.[13]

Types of alcohol licenses

At the time of the election, there are three classifications of retail licenses: on-premise license, special license, and off-premise license. There are four categories of retail liquor licenses: all alcoholic beverages (wine, malt beverages, and distilled spirits), wine only, malt beverages only, and wine and malt beverages. Currently, state law limits the number of all alcoholic beverage licenses to nine per establishment.[13]

For calendar year 2019, the ABCC reported 9,425 on-premise licenses, 3,052 off-premise licenses, and 28 package store licenses issued.[14]

Fines for selling to underage consumers

As of 2022, state law imposes a fine for selling to underage consumers that is equal to 50% of the daily gross profits on the sale of alcohol multiplied by the number of license suspension days. Fines are levied in lieu of suspension of a license.[15]

Consumer identification to purchase alcohol

At the time of the election, Massachusetts law did not explicitly authorize retailers to accept valid driver's licenses issued by another state as a form of identification to purchase alcohol. The law states:[16]

Any licensee, or agent or employee thereof, under this chapter who reasonably relies on such a liquor purchase identification card or motor vehicle license issued pursuant to section eight of chapter ninety, or on an identification card issued under section 8E of chapter 90, or on a valid passport issued by the United States government, or by the government, recognized by the United States government, of a foreign country, or a valid United States issued military identification card, for proof of a person's identity and age shall not suffer any modification, suspension, revocation or cancellation of such license, nor shall he suffer any criminal liability, for delivering or selling alcohol or alcoholic beverages to a person under twenty-one years of age.[6]

Alcohol on the ballot, 2022

Three initiatives related to alcohol were certified for the 2022 ballot in Colorado. One initiative was certified for the 2022 ballot in Massachusetts.

Year Measure Description Outcome
2022 Colorado Retail Liquor Store Licenses Initiative Incrementally increases the number of retail liquor store licenses an individual may own or hold a share in
Defeated
2022 Colorado Grocery and Convenience Store Wine Sales Initiative Creates a new fermented malt beverage and wine retailer license to allow grocery stores, convenience stores, and other businesses that are licensed to sell beer to also sell wine and conduct wine tastings
Approved
2022 Colorado Alcohol Delivery Service Initiative Allows retail establishments licensed to sell alcohol for off-site consumption to offer a delivery service or provide for a third-party alcohol delivery service
Defeated
2022 Massachusetts Changes to Alcohol Retail Licensing Initiative Incrementally increase the statewide limit on the combined number of retail alcohol licenses an establishment can have, including licenses for all alcoholic beverages and for wine and beer; prohibit self-checkout sales of alcohol; other changes
Defeated

Path to the ballot

See also: Laws governing the initiative process in Massachusetts

The state process

In Massachusetts, the number of signatures required to qualify an indirect initiated state statute for the ballot is equal to 3.5 percent of the votes cast for governor in the most recent gubernatorial election. No more than one-quarter of the verified signatures on any petition can come from a single county. The process for initiated state statutes in Massachusetts is indirect, which means the legislature has a chance to approve initiatives with successful petitions directly without the measure going to the voters. A first round of signatures equal to 3 percent of the votes cast for governor is required to put an initiative before the legislature. A second round of signatures equal to 0.5 percent of the votes cast for governor in the last election is required to put the measure on the ballot if the legislature rejects or declines to act on a proposed initiated statute. Signatures for initiated statutes in Massachusetts are collected in two circulation periods. The first period runs from the third Wednesday in September to two weeks prior to the first Wednesday in December, a period of nine weeks. If the proposed law is not adopted by the first Wednesday of May, petitioners then have until the first Wednesday of July (eight weeks) to request additional petition forms and submit the second round of signatures.

The requirements to get an initiated state statute certified for the 2022 ballot:

If enough signatures are submitted in the first round, the legislature must act on a successful petition by the first Wednesday of May. The measure only goes on the ballot if the legislature does not pass it and if the second round of signatures is successfully collected.

Details about this initiative

  • Question 3 was filed by Robert Mellion, the executive director of the Massachusetts Package Stores Association (MPSA).[1]
  • On September 1, 2021, the attorney general cleared the initiative for signature gathering.[7]
  • On November 26, 2021, MPSA announced that the campaign had gathered more than 80,000 signatures.[17]
  • On December 1, 2021, MPSA announced that they had submitted 109,000 certified signatures to the secretary of state.[18]
  • At the end of December, the secretary of state certified the petition to the legislature.[19]
  • The state legislature did not pass the initiative before the May deadline. The campaign was cleared to gather a second round of signatures.
  • On July 7, the state elections office reported that the initiative had filed a second round of signatures.[20]
  • On July 14, the secretary of state informed the campaign they had qualified for the ballot.[21]

Cost per required signature

Sponsors of the measure hired Spoonworks Inc. to collect signatures for the petition to qualify this measure for the ballot. A total of $723,500.00 was spent to collect the 93,613 valid signatures required to put this measure before voters, resulting in a total cost per required signature (CPRS) of $7.73.


Lawsuit

  
Lawsuit overview
Issue: Whether the initiative contains subjects that are unrelated
Court: Massachusetts Supreme Judicial Court
Ruling: Ruled in favor of the defendants; the subjects are related.
Plaintiff(s): Cumberland FarmsDefendant(s): Massachusetts Package Store Association
Plaintiff argument:
The initiative contains several subjects that are unrelated; therefore, the initiative should not have been cleared for circulation.
Defendant argument:
The subjects addressed in the initiative are mutually dependent.

  Source: The Eagle-Tribune

Cumberland Farms filed a lawsuit against the initiative arguing that it contained unrelated subjects. On June 13, 2022, the Massachusetts Supreme Judicial Court ruled that the initiative "presents voters with an integrated scheme” that “does not require a voter to cast a single vote on dissimilar subjects."[22]

How to cast a vote

See also: Voting in Massachusetts

See below to learn more about current voter registration rules, identification requirements, and poll times in Massachusetts.

How to vote in Massachusetts


See also

External links

Footnotes

  1. 1.0 1.1 1.2 1.3 1.4 1.5 Mass.gov, "Initiative text," accessed July 29, 2021
  2. Massachusetts State Legislature, "General Laws, Title XX, Chapter 138, Section 23," accessed August 24, 2022
  3. Massachusetts Package Stores Association, "Ballot initiative," accessed September 22, 2022
  4. Mass Live, "Massachusetts package stores association proposes to double liquor licenses available to any one retailer," accessed September 22, 2022
  5. Massachusetts Secretary of State, "2022 Information for Voters," accessed September 20, 2022
  6. 6.0 6.1 6.2 6.3 6.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
  7. 7.0 7.1 Massachusetts Attorney General, "Final Summary," accessed September 1, 2021
  8. 8.0 8.1 8.2 8.3 8.4 Massachusetts Office of Campaign and Political Finance, "Search," accessed July 7, 2022
  9. Massachusetts Secretary of State, "Official Voter Information Guide," accessed October 27, 2022
  10. MassLive, "More Mass. liquor licenses? How Ballot Question 3 could impact your community," September 29, 2022
  11. Massachusetts Secretary of State, "Official Voter Information Guide," accessed October 27, 2022
  12. Massachusetts Office of Campaign and Political Finance, "Ballot Question Spending Reports ," accessed October 24, 2022
  13. 13.0 13.1 Massachusetts General Laws, "Title XX. Chapter 138. Section 12." accessed September 19, 2022
  14. Mass.gov, "2020 Annual report," accessed September 19, 2022
  15. Massachusetts General Laws, "Title XX. Chapter 138. Section 23." accessed September 19, 2022
  16. Massachusetts General Law, "Chapter 138, Section 34B." accessed September 22, 2022
  17. WBUR, "Mass. liquor stores say they have enough signatures to advance ballot question," November 26, 2021
  18. WBUR, "Deadline whittles ballot question field to three campaigns," December 2, 2021
  19. Boston Globe, "Gig worker petitions move one step closer to 2022 ballot," December 27, 2021
  20. Victoria Antram, "Phone conversation with Elections Department," July 7, 2022
  21. Victoria Antram, "Phone conversation with Elections Department," August 9, 2022
  22. The Eagle-Tribune, "SJC ruling clears booze battle for ballot," June 14, 2022
  23. Secretary of the Commonwealth of Massachusetts, "The Voting Process," accessed April 13, 2023
  24. 24.0 24.1 24.2 Secretary of the Commonwealth of Massachusetts, "Voter Registration Information," accessed April 13, 2023
  25. Governing, “Automatic Voter Registration Gains Bipartisan Momentum,” accessed April 13, 2023
  26. 26.0 26.1 NCSL, "State Profiles: Elections," accessed August 26, 2024
  27. Secretary of the Commonwealth of Massachusetts, "Massachusetts Official Mail-in Voter Registration Form," accessed November 1, 2024
  28. Under federal law, the national mail voter registration application (a version of which is in use in all states with voter registration systems) requires applicants to indicate that they are U.S. citizens in order to complete an application to vote in state or federal elections, but does not require voters to provide documentary proof of citizenship. According to the U.S. Department of Justice, the application "may require only the minimum amount of information necessary to prevent duplicate voter registrations and permit State officials both to determine the eligibility of the applicant to vote and to administer the voting process."
  29. 29.0 29.1 Secretary of the Commonwealth of Massachusetts, "Identification Requirements," accessed April 13, 2023