COLUMBUS, Ohio — A federal judge has temporarily blocked enforcement of an Ohio law requiring people to provide proof of U.S. citizenship when registering to vote, putting the state’s voter-registration procedures back in the spotlight ahead of upcoming elections.
U.S. District Judge Solomon Oliver Jr. ruled that Ohio’s requirement went beyond the information necessary under the federal National Voter Registration Act, or NVRA. The ruling temporarily pauses enforcement of the provision but does not strike the law from the books. The underlying lawsuit will continue in federal court.
Ohio Secretary of State Frank LaRose immediately pushed back against the decision and said his office plans to appeal.
“We strongly disagree with that decision, and I’ve asked our legal team to file an immediate appeal,” LaRose said, according to NBC4. “I will vigorously defend our legal authority to safeguard our voter rolls and protect the integrity of Ohio’s elections.”
The provision at issue was included in House Bill 54, which Gov. Mike DeWine signed into law in 2025. It requires people registering to vote to provide documentation establishing that they are U.S. citizens.
The law was challenged by Red Wine & Blue and the Ohio Alliance for Retired Americans. The groups argued that Ohio’s requirements conflict with the NVRA, which requires states to provide voter-registration opportunities when eligible residents apply for or renew driver’s licenses.
The groups also argued that the documentation requirement could create problems for otherwise eligible voters who do not have citizenship documents that match their current legal names.
One example cited in the lawsuit involves married women who changed their names and could have difficulty producing a certified citizenship document matching the name on their voter-registration application.
Under the Ohio law, the state’s Bureau of Motor Vehicles changed its registration process so that voter registration was offered only after an applicant provided proof of citizenship.
Oliver found that process inconsistent with the federal law.
“Ohio has made the voter registration offer contingent on the success of a person’s driver’s license application,” Oliver wrote, according to NBC4.
The judge also pointed to the NVRA’s requirement that states request only the “minimum amount of information necessary” for voter registration. Oliver determined that Ohio’s additional documentation requirement exceeded that standard.
Ohio’s existing voter-registration form already requires applicants to affirm that they are U.S. citizens. Applicants also provide either a driver’s license number or the last four digits of their Social Security number.
The form contains a declaration signed under penalty of election falsification in which the applicant states that they are a U.S. citizen.
Oliver concluded those existing safeguards were sufficient under the federal law and did not justify Ohio requiring additional citizenship documentation as a condition of registration.
LaRose has argued that additional verification is necessary to protect the state’s voter rolls and prevent noncitizens from participating in elections.
He cited a recent Franklin County case involving an Ohio woman who admitted illegally voting as a noncitizen. According to LaRose, the woman said she registered after a BMV clerk told her to do so. A judge determined the BMV employee had misled her into violating Ohio law.
Voting by noncitizens is illegal and can carry criminal penalties, but documented cases remain relatively rare.
The Ohio dispute comes amid a broader national debate over whether voters should be required to provide documentary proof of citizenship. President Donald Trump has backed the federal SAVE Act, which would establish citizenship-documentation requirements for voter registration nationwide.
Other states have also faced scrutiny over voter-registration records involving people who were not eligible to vote.
NBC4 reported that New Jersey Gov. Mikie Sherrill said this summer that about 6,600 noncitizens had been registered to vote in that state between June 2023 and June 2024. She said about 400 of those individuals actually voted, while attributing the registrations to a software error rather than an intentional effort by noncitizens to participate illegally.
In Ohio, LaRose said in October 2025 that his office had referred 1,200 criminal voting cases to the U.S. Department of Justice. Among those cases were 167 noncitizens who appeared to have voted in at least one federal election between 2018 and 2024.
NBC4 reported that those 167 cases represented approximately 0.00005% of all votes cast in Ohio during that period.
The latest federal ruling does not determine whether Ohio’s citizenship-proof requirement will ultimately survive. For now, enforcement is paused while the legal challenge proceeds and LaRose’s office prepares an appeal.
The case could ultimately determine how Ohio balances its state-level requirements for verifying voter eligibility with federal requirements governing voter registration.
