Court reinstates Ohio law requiring proof of citizenship to register to vote ahead of midterms

WASHINGTON, DC: A federal appeals court on Wednesday, September 23, reinstated an Ohio law requiring people to provide documentary proof of US citizenship when registering to vote at state motor vehicle offices.

The 2-1 ruling by the 6th US Circuit Court of Appeals paused a lower court’s preliminary injunction that had blocked the requirement earlier in August, just 2 weeks before the state's voter registration deadline. The decision allows Ohio to enforce the provision ahead of the November 3 midterm elections.

6th circuit pauses lower court order blocking Ohio law

The case centers on an Ohio law enacted in 2025 that requires people registering to vote while applying for or renewing a driver’s license at a Bureau of Motor Vehicles office to provide documentary proof of citizenship. The provision was challenged by Red Wine & Blue and the Ohio Alliance for Retired Americans, which argued that the requirement conflicts with the National Voter Registration Act.

The federal district court in Cleveland had granted the groups a preliminary injunction in August, finding that the requirement likely conflicted with the federal law. US District Judge Solomon Oliver Jr, at the time, said a written attestation of citizenship was sufficient for election officials to determine eligibility and that requiring additional documentation could create an obstacle to voter registration.

However, the 6th Circuit’s ruling temporarily puts that injunction on hold. The appeals panel said that the groups challenging the law were likely to face questions over standing and also pointed to the timing of the lower court order, which came relatively close to the election.

The groups had argued that the National Voter Registration Act permits states to require only “the minimum amount of information necessary” to determine whether someone is eligible to vote. 

Circuit Judge Kevin G Ritz dissented from the appeals court decision. He pointed to individuals who, according to the case record, were unable to register to vote at a BMV office without first providing documents such as a passport or birth certificate.

Ritz wrote that those individuals “wanted to be afforded the opportunity to register to vote, without providing documentary proof of citizenship, when they applied for a driver’s license at a BMV location.” He added: “But they were not afforded that opportunity, because of the Ohio law at issue. That is enough.”

Ruling comes amid broader GOP push for voter requirements

The Ohio case falls in the backdrop of a wider push from Republicans and the Trump administration for additional citizenship and identification requirements for federal elections.

In February, the Republican-controlled House first passed the SAVE America Act, which would require proof of citizenship for federal voter registration and photo identification for voting. The legislation has since then been passed over half a dozen times in the House, however, it has been repeatedly stalled in Senate. 

Republican lawmakers have argued that such measures are intended to strengthen election administration and prevent noncitizens from being registered or voting. Democrats and voting-rights groups have argued that additional documentation requirements could create barriers for eligible voters.