Appeals Court Restores Ohio Law Requiring Proof of Citizenship to Vote

A split federal appeals court has restored an Ohio law that requires proof of citizenship to register to vote, overturning a recent injunction against the statute.

A majority of judges on a U.S. Court of Appeals for the Sixth Circuit said on Sept. 23 that organizations and individuals who sued Ohio officials over the law failed to identify any eligible, would-be voters who would be prevented from registering to vote by the law, which was enacted in 2025.

The law required workers at the Ohio Bureau of Motor Vehicles to offer to register to vote only to people who presented, or had previously presented, proof of U.S. citizenship.

The only individuals identified by the plaintiffs said they were never offered an opportunity to register to vote while at bureau locations. But bureau workers rejected those individuals’ applications for driver’s licenses based on paperwork defects, which does not implicate the law, according to the ruling.

The majority also said that a lower-court judge who had entered a preliminary injunction against the law likely did not have jurisdiction to enter forward-looking relief to the plaintiffs.

“On balance, the stay factors support Ohio’s request for relief,” Circuit Judges John Nalbandian and Whitney Hermandorfer, who formed the majority, said. “We therefore GRANT Ohio’s motion for a stay of the district court’s injunction pending appeal. We DENY Ohio’s motion for entry of an administrative stay as moot.”

U.S. District Judge Solomon Oliver Jr. had in August blocked the law, concluding that its requirements went beyond “the minimum amount of information necessary” to register to vote under the National Voter Registration Act, which sets out the process for states to let people register to vote when applying for or renewing driver’s licenses.

Ohio Secretary of State Frank LaRose, a Republican, on X called the new ruling a “huge legal victory for election integrity in Ohio.”

The organizations that brought the lawsuit have not commented on the decision.

Circuit Judge Kevin Ritz, who was also on the panel that considered the case, dissented.

Because the National Voter Registration Act requires voter registration to be offered to people who submit a driver’s license application, even people who submit defective applications should be offered the opportunity to register to vote, including the people named by the plaintiffs, Ritz said.

“But Ohio’s new state law requires driver’s license applicants to show documentary proof of citizenship before Ohio will offer them a voter registration form,” he wrote, a requirement that conflicts with federal law.